THE OF FEDERAL PROGRAM:

WETLANDS NEVADA

U.S. Fish and Wildlife Service G re at Basin Complex, Reno, N e v a; i a October 198G TABLE OF CONTENTS

Introduction j

Methodology «

Riparian -jnd Wet Meadow Wetlands 4

Palustrine Emergent and Lacustrine Wetlands 6

Ecosystem Values 5

Riparian and Wet Meadow Wetlands 6

Palustrine Emergent and Lacustrine Wetlands 8

Description of Original Acreage 13

Riparian and Wet Meadow Wetlands 13

Palustrine Emergent and Lacustrine Wetlands 13

Current Acreage and Trends 14

Riparian and Wet Meadow Wetlands 14

Palustrine Emergent and Lacustrine Wetlands 18

Federal Programs Involved in Wetland Loss 19

Riparian and Wet Meadow Wetlands 19

Palustrine Emergent and Lacustrine Wetlands 25

Future Vulnerability 31

Riparian and Wet Meadow Wetlands 31

Palustrine Emergent and Lacustrine Wetlands 32

Recommendations 36

Riparian and Wet Meadow Wetlands 36

Palustrine Emergent and Lacustrine Wetlands 37

Literature Cited 39 INTRODUCTION

Nevada lies completely within ihn In t ermoun t ain Ee^ion of North America. This region is circumscribed on the west by the Sierra Nevada and Cascade Ranges on the north by the Lahontan basin in southeastern Oregon the Snake River Plain, on the oast by the Utah/Colorado border, and on the south from the Four Corners area across southern Nevada into east-central California (Cronquist et al. 1972). The Intel-mountain Region includes several physiographic provinces: rhe Great Basin province being the province which mostly includes Nevada (Nolan 1343. Morrison 1961:1 'Figure I). As rhe name Great: 3 a-: in implies, regional stream flow does not reach the ocean but remains land locked. Precipitation failing in the region flows into broad valleys where it percolates into ground water resources or evaporates. The topography of Nevada is characterized by numerous northeast - southeast oriented mountain ranges separated by deep valleys. N i n e t y-t w o Mountain ranges lie • v i th i n N e v a d a. T he e i • ti re S tat e lies at a relatively high elevation: mountain peaks range from 6,000 feet to 13,000 feet elevation and valleys average slightly more than 3,800 feet elevation.

Topography of the State combines with its geographical location to create a wide array of climates. Mountain ranges in the northern two-thirds of the State receive an average 11-13 inches of precipitation annually while mountains in the southern one-third receive 7-9 inches annually (Beatley 1975). The amount of precipitation falling on the valleys follows a similar north- south trend. Northern valleys receive approximately 7-9 inches of precipitation annually and southern valleys receive 4 inches annually (Billings 1949, Beatley 1975). Most of the precipitation in northern Nevada falls as winter snow, whereas the southern portion of the State receives most of its moisture during summer thunder showers and autumn rains (Beatley 1975). All of the State may go many months without precipitation. The State is arid not only because of low precipitation, but also because of a high rate of evaporation which quickly dries soils and vegetation. Some areas in southern Nevada may receive 2 inches of rainfall annually and have an annual potential pan evaporation rate of 100 inches.

Since there are no outlet streams to drain the wetlands, and evaporation typically exceeds precipitation in the Great Basin, salts are removed from wetlands only during periods of high ^ ORE

CALIFORNIA

N

Figure 1. Nevada and the Great Basin province. r un •; f f . Salts mostly accumulate during dr-'.-ughts •v.'iL-ora t ion ran:- greatly exe-eds precipitation. 3'iUijTi'.: vegetation is reduced, replaced by l.^s.3 desirable '.-•*:.>•? t a i ; on , or e i 121 :ia t ed .

Topography, geographic location, and variant climates create a wide array of environments supporting numerous vegetation types. Montane vegetation types in the northern portion of r.he State include large conifer species such as ponderosa pine Pinus B2Q£§1~2§2) • tthite bark pine rPinus alb i caul li.s ', limber pine 'E.lDy§ fl§Zilii§';> bristlecone pine 'Pinus Ip.ngaeva" , and lorigepoie pine (Pinus contorts var. murravara''• .'Siireve 1342. Billings 1949'.

Montane communities in southern Nevada are predominantly pinyon (Pinus raonoghylla)/juniper (Junigerus spp.'> woodlands also populated by sagebrush (Artemesia tr iden^a t n '• . Vallevs in northern Nevada are predominantly sagebrush and valleys in southern Nevada are dominated by creosote brush iLarrea tri^entata) or burro brush (Ambrosia dumosa) ( Shreve 1S42, Cronquist e t a 1. 1972''.

-is a function of th<- arid climate, Great Basin v/et lands ': always been relatively restricted and small when ccmpartd wil;h those in more mesic regions. This does not mean, rn-.vever, that they are insignificant to wildlife or man. The dependency or. water of all human activity and most wildlife suggests, to the contrary, that they have a proportionally greater importance in arid environments than they do in regions with greater precipitation. The types of wetlands found here are also quite different from those found in more mesic environments. Following the U.S. Fish and Wildlife Service wetlands classification, Nevada wetlands may be classified as Palustrine-Fores ted, Palustrine Scrub-Shrub, Palustrine-Emergent, and Lacustrine wetlands. Within this classification, riparian wetlands are included within the Palustrine-Forested and Palustrine Scrub- Shrub types which are defined as freshwater habitats dominated by- trees that are 20 feet tall or taller, shrubs, and have the following four particular characteristics: (1) Small, less than 20 acres in area; (2) bedrock and features formed by wave-action are absent; (3) water depth is less than approximately 6 feet; and (4) salinity contributed by ocean-derived salts is less than 5 percent. The riparian zones are also characteristically flooded on a seasonal or intermittent basis (Cowardin et al. 1979). The difference between Palustrine Forested and Palustrine Scrub-shrub is the percent cover contributed by the over-story layer of vegetation. Palustrine-Emergent wetlands are defined as including characteristics 2 through 4 of those listed above, and by including erect, rooted, and/or herbaceous phreatophytes excluding lichens and mosses. Most plant species present during the majority of the growing season are perennial.

The Lacustrine System includes wetlands and deepwater habitats with all of the following characteristics: (1) Situated in a topographic depression or a dammed river channel permanently flooded lakes and reservoirs'-: (2'' lacking trees, shrubs, persistent emergents, emergent mosses or lichens with greater than 30 percent aerial coverage; ana •.'H; total are:i exceeds 20 acres. Ocean derived salinity is always less than 0.5 percent. Typically, Lacustrine Systems are extensive areas of deepwater: however, islands of Palustrine wetland may lie within their boundaries •'Coward in et al. 1979).

Federal programs have significantly affected the quality and quantity of wetlands in Nevada. These affects are due to the large proportion of Nevada that is administered by Federal land management agencies ;'87 percent; and the importance of water development projects in arid river basins with terminal wetlands. Reclamation projects have substantially decreased the size of some wetlands, completely eliminated others, and benefited none. Land management practices such as grazing" have detrimentally impacted virtually all of the riparian and wet meadow habitats in the State. Other programs such as herbicide spraying to decrease willow growth in riparian areas have also decreased riparian wetlands.

METHODOLOGY

Meadow Wetlands

There is little information which quantifies the amount and quality of wetlands in Nevada prior to pert urbat ing' activities. This is largely a function of early settlement of the region by- homesteaders. However, information does exist which provides a general overview of historic conditions so that trends in wetland acreage can be estimated. Also, a substantial amount of documentation exists showing complete recovery of wetlands when perturbating activities are ceased. This permits back- calculation to estimate the probable amount of wetland habitat existing prior to alteration.

Riparian zone management has received increasing attention during the past several years. This has spawned an increasing amount of literature and initiated the organization of several symposia focusing on the subject. Much of the information presented below is compiled from this literature. The U.S. Forest Service (USFS) and U.S. Bureau of Land Management (BLM) have responded to this increased interest by frequently including data showing the condition and trends of existing riparian areas on lands under their jurisdiction in various environmental impact statements prepared for their grazing programs (BLM) and general land management decisions (BLM and USFS). Other information is available which also permits inferential analysis of existing riparian wetland condition. This is provided from quantitative analyses of stream habitat conditions that have been collected by USFS and BLM during surveys conducted in cooperation with the Nevada Department of Wildlife (NDOW). Although these surveys focused on the immediate aquatic environment, they consider bank vegetation cover and bank stability parameters in cal culat i r. j aquatic habitat quality. Therefore, -von -hough these da! a do not specifically address the quality of streamside riparian wetlands, they indicate existing conditions. Confidence In !;ojn:,r these data in this manner is supported by statements in BLM summar?; reports which state that the major parameters causing poor quality in aquatic habitats are those due to over utilization of stream banks by livestock (USBLM l'383a, b, c; 1384a, c) . Consideration of support; provided by the Federal government to m a k e projects affecting wetland condition economical were collected from BLM, NPGW, and pertinent literature.

Although the lack of data makes it difficult to determine the existing amount of riparian and wet meadow wetlands in Nevada, an indication of its extent can, however, be estimated by analysing information that has betn collected to describe stream condition. Unfortunately, much of these data have been collected from local sites, however-, sufficient data has been collected to r e p r e s e n t the existing conditions throughout t h •-; state. Estimating the amount of existing' wetlands is also complicated because the existing quality ^f many a'~eas has deteriorated to the extent that, vegetation types and so; '. moisture may remain indicative of riyaria;; and wet meadow wetlands, but the quality is so degraded that it is no lon utilized by wildlife and affords no watershed protection.

Stream quality is determined using the methodology -descr in Duff and Cooper (1976). This estimate averages values for th^ parameters of pool quality, pool- riffle ratio, bank stability, bank cover, and instream cover to compute a grand mean which indicates the percent of optimum a habitat is for trout. Data is collected along transects; five transects are taken every 100 yards at a single site for every mile of stream surveyed. Since several of these parameters are the same as those characterizing streainside riparian condition, it is possible to utilize these as indices of riparian wetland condition.

Streamside riparian condition is further quantified on lands within the Toiyabe Natonal Forest by surveys that have considered channel stability and bank sensitivity. Channel stability is estimated by quantifying the following parameters: 1-Bank slope; 2-recent evidence of erosion; 3-bank vegetation density; 4-size and angularity of boulders in bank; 5-evidence of raw banks; and 6-substrate size. Bank sensitivity is a function of upper bank slope, upper bank erosion, upper bank debris, upper bank vegetation cover, lower bank rock content, and lower bank cutting. Both of these indices estimate condition by assigning numerical values to characteristics of surveyed sites. The USFS has found strong correlations between the condition of bank sensitivity and the impact of grazing (Cooper 1979). When possible, historical and present acreage quantities for Palustrine Emergent and Lacustrine wetlands was taken from available literature: i.e., Pyramid Lake 'Harris 1970 , and Humboldt Sink fUSFWS 1981a; .

Winnemucca Lake fluctuated greatly, being dry in some years, but with a maximum of 62,400 surface acres of water and marsh (Osg'ood and Miller 1339). Since it varied so much, an average of maximum and minimum acreage was used to obtain a historical figure. Since 1938 Winnemucca Lake h :3. s been dry.

Historical acreage for the Stillwater Area (comprising Stillwater Wildlife Management Area and Carson Sink) was calculated using combined average discharge flows from the East and West Forks of the Carson River (USGS 1985'.. Then dividing that total by 5 acre-feet, the amount of water needed to maintain one surface acre of wetland for 1 year (USFWS 1981 a; an average acreage of total possible wetlands was reached. By subtracting a 1882 figure for Carson Lake wetlands 'Nevada Department of Wildlife 195_a) we obtained the Still water Area historical acreage.

Present acreage for Carson Lake and the Stillwater Area fluctuates not only yearly but monthly depending upon water availability arid weather. So a single figure does not accurately represent the true conditions. The single figure, shown in Table 1 P • B\ » was obtained by averaging 6 years acreages, which themselves are an average of January, September, and December acreages (Osugi 1973, 1974, Osugi and Barber 1976, Barber 1976, 1977, 1978).

To determine the number of potential acres of wetlands lost due to future management actions, the number of acre-feet of water saved (and thus not delivered to the wetlands as agricultural return water) was divided by 5 acre-feet which is the quantity of water required to maintain 1 acre of wetland for 1 year (USFWS 1981a) . Where applicable the quantity of water saved is multiplied by 35 percent (Nevada State Engineers Office 1974) to adjust for the water lost to evapot ranspirat ion before reaching the wetlands.

ECOSYSTEM VALUES

Wet Meadow Wetlands

Riparian wetlands cover a small portion of the total area within Nevada. They characteristically border streams, extending as much as 100 feet from either bank and will, therefore, occur as winding trails through the expanse of bordering s/eric soils and their associated vegetation. As such, they are restricted to valley or fiver bottoms where they are dom in an 'r. f e a i .\\r -:•. s of the landscape which indicate the presence of water. The" a •••• the single :nos': occupied habitat of any vegetation type w;r L n t n e region. Thomas et al. (197:?; nobed that of 1163 species o 11 r> within the Great Basin of southeastern Oregon. 230 or percent of them depend during some portion of their I if ~ cYc_; e on riparian habitat. This dependency vari-s with '•he spec: .es but. its importance includes utilizing the area as a food so a r c e , as nesting s i t v s , a s living area, and as cover •' D e a 1 e y e t a i . 198 1 • . Stevens et ai . ('1377; summarized the importance of riparian habitats to migrating birds by presenting data showing that riparian areas support up to 10.fi times; th-r number of migrants per nrea at do adjacent non-riparian areas. 'Numerous other authors presented data supporting the conclusions by Stevens et al. (1377';. Boeer and Schmidly . 1977^. discussed the importance of riparian areas to mammal populations and report that degradation of these a re at; caused the elimination of one species and declines in two others in s t u (i i e s conducted in Big Ben d National Park.

Fishes occupy waters supporting riparian areas and are, therefore, immediately impacted by activities affecting their status. Riparian zones provide a a umber of functions for -^hreanis and their fishes: ' 1 , They provide shade which prevents sunlight from warming water to temperatures above those tolerated by many- game fishes: (2'; leaf litter dropped by riparian vegetation is the primary source for nutrient input into streams ;Cummins 1974); (3) vegetation provides hydraulic controls which maintain stability in the stream environment by decreasing or eliminating deleterious scouring and/or siltation during flood events and thereby maintaining the maximum possible diversity in aquatic habitat. Studies conducted by a number of authors document, the close relationship between fish population status and stream bank vegetation (Gunderson 1968, Keller et al. 1979, Van Veison 1979, Platts 1981).

The diversity of vegetation in riparian areas also serves as habitat and food resources for insect fauna. This fauna then serves as a food resource for birds and fishes.

Riparian zones also serve several other values. When they are in good condition, they function to minimize erosive forces that remove soil that contribute to downstream siltation problems (Cordone and Kelley 1961, Kennedy 1977). In this regard they protect watersheds by holding soils in place by preventing downstream movement of nutrients and top soil. They also provide for substantial recreation opportunities (Behrens-Tepper et al. 1985) in Nevada where riparian vegetation provides the only shade in an otherwise very warm and sunlit environment. Most campsites, managed and unmanaged, are situated where riparian trees provide cover, shade, and greenery. Because of the availability of water, forage, and fuel wood many homesteads included some riparian lands. P ! lus.tr j_n

Palus t. rine emergent and lacustrine .vetlands In X^vadu are unique because they are located at the terminus of the major river systems within the Great Basin. These wetlands are unlike flow through systems where flushing occurs and much of the salts are ultimately deposited into the ocean. Here, all sal is, hea<-y metals, and other substances accumulate because there is no out let .

Four m a j o r river systems terminate in Nevada to form lakes or marshes. The Truckee and Walker River systems originate in the Sierra Nevada mountains of California and terminate as 1 a k <•;• s in. Nevada. The Carson and Humboldt Rivers also originate in mountainous areas and terminate as marshes in Lahont.an Valley.

Pyramid Lake (lacustrine system'; supports the threatened Lahontan cutthroat trout : Salmo clarki. henshawi) which is the largest subspecies of cutthroat trout, and the endangered cui-ui .s t es cujus} which is endemic to the lake.

The pal u s trine wetlands, p a r r. i c u 1 a r 1 y t h o s e •; 1 us t e r e d i i: west-central Nevada, are essential habitat for migratory waterfowl on the Pacific Flyway. Great expanses of arid land separate these islands of habitat. They are irreplaceable links for migratory birds between the M a 1 h e u r marshes of Oregon, the Bear River marshes in Utah, and wintering areas of California and Mexico. Loss of these key areas would necessitate m a .; o r changes in the flyway patterns, which would probably bypass Nevada entirely (Pyramid Lake Task Force 1971). Waterbirds able to survive alternate migration routes would be forced to migrate to other areas where they would compete for food with birds already us ing the areas .

Pyramid Lake, within the Pyramid Lake Indian Reservation, is at the terminus of the Truckee River and it covers an area approximately 25 miles long by 4-10 miles wide (Figure 2). The Truckee River is Pyramid Lake's primary water source. Two federally-listed fish species depend upon Pyramid Lake. The threatened Lahontan cutthroat trout supports a valuable sport fishery that has recently produced trout weighing up to 19 pounds. The endangered cui-ui is endemic to Pyramid Lake. Prior to 1979 the cui-ui provided subsistence food to the Pyramid Lake Pauite Indian Tribe (USFWS 1981b).

Anaho Island in Pyramid Lake is 749 acres. Two hundred and forty seven acres of the island make up a National Wildlife Refuge. Nesting colonies of white pelicans, double-crested cormorants, California gulls, great blue herons, and Caspian terns occupy the island (Woodbury 1966). Anaho Island is the only persistent white pelican nesting site in Nevada and is the largest of eight nesting colonies for the American white pelican in the western United States and Canada (USFWS 1982).

8 \ W!NNEMUCCA\ LAKE (DRY) /

I J

\

1 \ / 1 V \ , 1 / \ 1 I J /- ANAHO ISLAND s NATIONAL WILDLIFE REFUGE r o (/ «-' /ff MARBLE BLUFF FISH FACILITY

PYRAMID LAKE AREA

MILES 01 234 5 tN Winuemiic;:;.: Lake (dry;, 8 miles east of Pyramid Lake, was connected to Pyramid Lake via the Mud Lake Slough •;'Figure 2, prior !" o 1028 when its marsh-1 yp^ wetland habitat was permar.enrl dried due to water diversions created by a Reclamation project. Winnemucca Lake was well known as a major waterfowl hunt In i; area in the late ISOO's and early 1900's-. On August 19. 1936, Winneinu'jca Lake was designated as a National Wildlife Refuge under Executive Order 7435; however, by the time this order was issued, Winnemucca Lake was nearly dry. In 1962 Win.nemucca Lake was officially removed from National Wildlife Refuge status (Nevada Department of Wildlife 195_h:.

The Carson River flows into a series of wetlands at its terminus in the Lahontan Valley. The largest of these areas are: The Stillwater Wildlife Management Area '. S t i 11 wa t er .; . Canvasback Gun Club, arid Carson Lake -.'Figure 3). These wetlands support 75 percent of the State's waterfowl use days, 50 percent of the State's Canada goose population, and 65 percent of the State's whistling swan population (Nevada Department of Wildlife 1984,. Twenty five percent of the State's bald eagle population utilize the Lahontan Valley wetlands as winter feeding habitat. The Anaho Island white pelican colony makes daily feeding flights from Anaho Island to the wetlands during the spring. In 1986 white pelicans also used Stillwater for nesting (Steve Thompson, personal communication, USFWS, Fallen, Nevada';. The long-billed curlew, mountain plover, and white-faced ibis utilize these wetlands. These birds are candidates for Federal listing on the threatened and endangered species list (USFWS 1985a).

One-third of the Pacific Flyway population of car.vasback ducks use Stillwater for feeding' and resting during migration (Norm Saake, personal communication, NDOW, Fallon, Nevada). Stillwater also provides nesting habitat for waterfowl--primarily redheads. It is of critical importance because the continental population of canvasback and redhead ducks is low (Pyramid Lake Task Force 1971).

Carson Lake provides habitat for the largest concentration of non-game birds in the State including breeding population of American avocets and black-necked stilts (Nevada Department of Wildlife 1984). Carson Lake provides habitat for the largest of seven active breeding colonies of white-faced ibis in Nevada and is one of the three principal nesting colonies in the western United States (USFWS 1985c, Pyramid Lake Task Force 1971).

Carson lake also provides habitat for the peregrine falcon which is on the Federal Endangered Species List. Six confirmed sitings of peregrines were made at Carson Lake in 1986 (Steve Thompson, personal communication, USFWS Fallon, Nevada).

The Humboldt Wildlife Management Area is a large natural wetland area at the terminus of the Humboldt River (Figure 4). Redhead ducks have comprised up to half of the nesting duck 'ERMLEV STATE WILDLIFE MANAGEMENT AREA

STAMPEDE RES INDtriNDfMCt J ITIU.WATEH POINT jjS* DOOA

ILAHONTAN RESEBVOIR

CAR8OH LAKE PASTURE

[LAKE TAHOE PAM|

LAKE TAHOE Figure 3. NEWLANDS PROJECT

I Major features V/////////A Service area WINNEMUCCA

Woler Rights Acquired for—"£jj Projed Woler Supply

Lands Acquired for Development "^ ["^ of Projed Water Supply RYE PATCH RES PITT-TALOR DIVERSION CANAL

PITT-TAYLOR RES

RYE PATCH DAM

TOULON LAKE _ / Pershing Counly Woler Conservation

HUMBOLDT SlNK^g/ ///////,

/r ^ S////Y'///'"' J?^ • ////.\.. .y//////////j^jgCARSO N//,, SIN '.j

en National Wildlife Refuge

Figure 4. THE HUMBOLDT PROJECT

12 population. In unusual circumstances Hie area mav become the most important area in Mevada. During the 1577 drought it provided more waterfowl use-days than Carson Lake and S combined (USFWS ISSla';.

DESCRIPTION OF ORIGINAL ACREAGE

Wet Meadow Wetlands

Wetland extent is nacuraiiy limited by topography and to a great extent by availability of water. Several authors calculate t h a t riparian wetlands cover less t h an 1 percent of the land in Nevaia. Data is lacking which quantifies the historic amount of riparian wetlands in Nevada; however, the rej uv inat ion of stream- side vegetation to near pristine conditions following the removal of perturbating activities ''Dahlem 1979, Crispin 1981 '• indicates that these wetlands were associated with all flowing water in Nevada. The amount of riparian wetland can, therefore, be estimated by considering the amount of stream In the State pri-r to perturbation and using the approximate width of riparian z o n e H that presently occur along unaltered streams. Walstror.i :'197!J; estimated that 7,500 miles of stream occurred in Nevada prior to p e r t u r b a t i n g a c t i v i ties o f c h a nnelizarion, d i v e r s i o n , a n d o v «_- r grazing, and BLM estimates that the riparian corridor averages 100 feet in width. Therefore, approximately 30,900 acres of riparian habitat historically occurred in Nevada. There is no information indicating the quality of the wetlands prior to perturbation. This may be estimated, however, by considering the condition of riparian habitats that have recently been protected from perturbating activities. In all such situations, the removal of perturbating activities has resulted in the reestabl ishment of riparian wetlands in excellent condition (Dahlem 1979, Crispin 1901). It is, therefore, valid to assume that all 90,900 acres of streamside riparian habitat historically present in Nevada was in excellent condition.

The amount of wet meadow vegetation during historic times is more difficult to estimate since there has never been an attempt to survey either their condition or size. The nature of these wetlands makes them difficult to survey; they occur usually as isolated sites maintained by springs or seeps that may not be reached by vehicles. For the purposes of this analysis, therefore, the only information considered for these wetlands will be that which has been compiled for specific areas by BLM and USFS. This does not permit an estimate of the total, but it does allow consideration of quantities and their quality in particular locations.

E§.Iu§i.rine l5§Ig§Qi §Hd Lacustrine Wetlands

Historically the Truckee River flowed into Pyramid and Winnemucca Lakes; Carson River flowed into Carson Lake, then through Stillwater Slough to Carson Sink. After the Bureau of

13 Reclamation's Newlands Project came on line a portion of the Truckee Hiver was diverted to L ah on tan Reservoii- which was erected by dairying' the main Carson River. Diversion of the Truckee River caused the Pyramid Lake water level to recede 3Q feet in 59 years (Harris 1370. and "Winnemucca Lake to dry- completely by 1930. Truckee and Carson River water impounded by Lahontan Dam is first used for irrigation purposes and/or the generation of electric power below the Dam. Agricultural drainage water is then used for maintaining wetlands in Carson Lake and Stillwater Wildlife Management Area (including much of the Carson Sink). Historic acreage versus present acreage is s how n in T a L1e 1 .

i h e Kumboldh um D o ; <.t; t RHiI \e r in no r r.n nw o es r ter f hwne sN t e e v r a n d aNevad w as aa ,1 t e r e: Humboldt Irrigation Project which stores the remaining natura flow of the river in Rye Patch Reservoir for later use in the Lovelock, Nevada, area. The spill water and irrigation drain water is then sent to the Humboldt Sink for maintaining wet lands which provide an irreplaceable link migratory birds that use the Pacific Flyway. Table 1 shows the a c r e a! loss due t ;> reduced flow into the sink.

Table i—Average Acreage of Historic and Present Extent of Wetlands in Nevada and the Number of Acres Lost.

Hist o ri c a 1 P r- e s e n t Acres Project Acreage Acreage Loss

Newlands Project: Pyramid Lake 140,800 115,250 25,550 Winnemucca Lake 31,200 -0- 31,200 Carson Lake 25,000 10,000 15,000 Stillwater Area 49,000 11,400 37,600

Total "2467660" 136,650 109,350

Humboldt Project: Humboldt Sink 58,000 12,837 45,163

CURRENT ACREAGE AND TRENDS

0 §nd Wet Meadow Wetlands It is impossible to estimate the riparian and wet meadow resources of Nevada because surveys have not been conducted to determine either the amount or condition of existing riparian and wet meadows wetlands. Estimation of quality is also complicated by consideration of wetland quality because livestock utilization has degraded much of these wetlands so that they now offer few

14 co either watersheds or wildlife. Table 2 summarises the am<;un:: and '}uality of riparian wetl.ind.s thai: have beer. visited by investigators conducting stream surveys. These data :irci compiled from r.'SFS files and BLM planning documents '.US ELM 1973; 1980; 1981a, b; 1982a,b,c; 1933a,b,c; ]984a,b;. As explained in the M e b h o do I o g y Section, these data d o n o t repress n t specific information collected to quantify the condition and quantity of riparian and wet meadow wetlands. For wet meadow wetlands, the data in Table 2 was accumulated during site visits that did not include any quantification of sizfi or quality. For riparian wetlands they summarise the quantify of perennial streams and their suitability as trout habitat. Even though these data do not, specifically pertain to riparian wetlands, they have been used by land management agencies as estimates of riparian wetland size and condition. Both USFS and BLM biologists concur that these data indicate the size and extent cf these wetlands; however, it is also generally believed that they over estimate quality because they include consideration of parameters such as pool-riffle ratio and pool quality that are paramet e r s not influenced by riparian conditi o n . •p her t?f >r f\ s t ream w it h good p o o i - r i f f 1 e ratio and/ or pooi qua ]^ i t y b : t. r i D a r i a» -, (*- etlands in poor condition would be \* a t ed ~* s '- ~- (.^ ;; . .' -^ :^ b e 1 1 e r £ on dition than it would if only ripari a n c oT! d i t 1 O ) ',v e r e -; .., ,, •j cons i d ei" O *_* •\ s o , these data do no! 'nrlude r 'i r-- a r Tv <~^ a n ! : • - assoc ia t. ed with intermittent streams or aspen ood i a n d•^ TO t- associa t ed with surface water. Even with the s e sh o <: o 1 i- n g s , these data do provide an insight into existing conditions.

The USFS and BLM have recently completed preparing comprehensive management documents describing how lands under their jurisdiction will be managed for the next 10 to 20 y-ars (USBLM 1983a; 1984c, d, e, f ; 1985b,b,c: USFS 1986a, b ':• . Specific goals for quantity and quality of riparian and wet meadow wetlands are typically discussed only in general terms in these documents. While these documents discuss management of both wetland types, riparian wetlands are the most thoroughly considered because of the disproportionate amount of existing information indicating their extent and condition. These data also permit an analysis of trends in condition and quantity. Table 3 summarizes how these proposed management schemes will affect these wetlands in the future.

Interpretation of information presented in Table 3 is somewhat difficult because of inconsistencies in reports from which data are compiled. The following are submitted as examples of these inconsistencies. All of the plans state they will implement actions to improve riparian wetland conditions, however, most do not indicate goals for the amount of area to be improved or the anticipated conditions resulting from management.

15 Table 2- Estimated quantity and quality of riparian and wet meadow wetlands on USFS and 3LM lands in Nevada.

U.S. Bureau of Lan<\t Land;

Acreage Wet Meadow Acreage

Are; Excel/ Fair; Excel r air. '.i <•> o d P o o r Good Pnoi

Ely District 1,279 5,217 11,196*

Elko District 1,819 11,625 10 ,573*

Las Vegas Unknown Unknown District

Carson District U n k n o w n U n k n o w n

Winneniucca 2,211* 9,725* Unkn own District

Battle Mountain Unknown U n k n o w n District

U.S. Forest Service Lands

Acreage Wet Meadow Acreage

Forest Excel/ F air/ Excel/ Fair/ Good Poor Good Pool-

Toiyabe 17,778 20 ,048 Unknown

Humboldt Unknown Unknown

*Condition unknown. Surveys conducted on 5,782 acres. Condition ratings of this .' surveyed area expanded to all riparian acreage within District.

16 Table .1. Anticipated trends in riparian arni ivet meadow wetlands as presented in USFS and BLM land maiiageinen r resour: p I a n s .

U.S. Bureau of Land Management Lands

Are a Riparian Wetland W e t M e a d o w W e 11 a n •. j

Ely District Improve, no goals I~i2 kn ow n for acreage or c o n d i t i o n

Elko Improve to good Unknown District condition 3,480 acres

Las V e ^ a s I ;n p r- o v e 55 a c r e s , Decline D i s t r i c t. no goals for c o n d L t i o n

Carson Increase protection Improve 103 a c r ^: District of 524 acres. No no goals f o r goals for condition c o n d L t ion

Winnemucca No planning No planning District document document

Battle Unknown Unknown Mountain District

U.S. Forest Service Lands

Forest Riparian Wetland Wet Meadow Wetland

Toivabe Improve, goals set Unknown for only streams with threatened spec ies

Humboldt Improve, no goals for Unknown acreage or condition

17 In some of the documents, anticipated quantity and quaiitv goals to result from management actually represent maintenance of status quo or degradation from existing conditions ; e. u". , US3LM 19S4d, e). It may also be difficult to implement management thai. improves conditions on some BLM lands because policy directs th_e_s_e_jprojects may proceed only with the approval of holders the grazTngpermits. In many instances, contrary permittees prevent implementation of necessary management techniques. Therefore, the absence of quantified goals and limitations on the ability to implement necessary programs indicate that these wetlands will largely continue t o de t er i or at e or remain i n existing condition and size.

Diversion structures have existed for many years in Nevada. They were typically constructed to facilitate crop and pasture production. Although their construction was active during the early portion of this century, recent construction has been minimal because there are few streams or rivers remaining near agricultural lands that have not been fully developed. Many of these diversion structures were developed with assistance from the U.S. Department o f Agriculture; however, the antiquity n f most of these structures has meant that records of funding and date of construction no longer exist. How much these projects have affected the riparian wetlands is unknown. The extent of disturbance is believed to be substantial simply because almost every permanent 'stream located close to a ranch has been diverted for irrigation.

The U.S. Department of Agriculture has also been involved in herbicide spray programs to eliminate riparian vegetation as a means to improve pasture quality and irrigation. Although this activity continued for many years, few records have been kept to show the extent of treatment over' the years.

P§ly§tri.ne !m§rg§Qt §D<3 Lacustrine Wetlands

Development of arid land for agriculture by the Bureau of Reclamation uses water that historically reached the wetlands and consequently, wetland acreage trends have been downward. However, recently there has been a small upward turn due to exceptionally high water years. Terminal wetlands and lakes are largely dependent upon runoff and recent wet years have benefited Pyramid Lake and some portions of Lahontan Valley wetlands.

The remaining acreage of the Lahontan Valley wetlands, shown in Table 1, while not in danger of being lost through conversion to farmland, are in danger due to lack of water and degraded water quality. Proposals designed to save the threatened and endangered fisheries at Pyramid Lake may result in less water diverted to the Lahontan valley wetlands. Unless mitigation measures are implemented to provide sufficient quantities of high quality water to make up for these potential losses, the majority of these wetlands could be lost.

18 FEDERAL PROGRAMS INVOLVED IN WETLAND LOS

Wetlands

A number of Federal programs have either reduced the size or quality of riparian and wet meadow wetlands by permitting, funding, or conducting per turbat i ng activities. Three particular activities have had the_g_re_a_t es t _ in f 1 uence . In order of magnitude these are: fJPermi t t ing excessive livestock gra z i \\:^; 2-funding and / or permitting' ease .n.i e :i t s f o r d i v e r s i o n s t r u < • t. u r e s : and 3 f- funding herbicide application on private lands. Other programs that have had minor affects on these wetlands are road construction, recreation, and mining.

Livestock initially impacted lands when the west was homes teaded. At this time the livestock industry was supported by grazing on all public lands where there were no restrictions on hern size or the amount of permissible forage utilization. It was during the period prior to 1910 that livestock had th-> greatest impact on range conditions in the west. 'Bryan 1:;2", Leopold 1351, Antevs 1952). These initial impacts decreased in later times because fewer livestock could be supported on the remaining' forage. The magnitude of early impacts is probably unsurpassed by any other single activity that has degrade d t h e southwest environment. Direct and indirect impacts were immense and so dramatically changed the character of the land that results remain evident today (Robertson and Kennedy 1954, Brotherson and Brotherson 1981). Direct impacts included trampling and grazing which degraded riparian wetlands. The indirect impacts of trampling vegetation and excessive vegetation removal destabilized watersheds and permitted flooding which scoured stream channels and further deteriorated riparian wetlands (Bryan 1925, Leopold 1951, Antevs 1952).

The disposition of Federal lands since the mid-1800's has influenced recent impacts of grazing on vegetation and watersheds. By the 1920's some lands had been segregated into administration by the USFS and other agencies, some of which had specific management goals incorporated into their charters which directed basic land management practices, e.g., the USFS was required to protect watersheds, the Bureau of Sport Fisheries and Wildlife to enhance wildlife. Remaining Federal lands, which have since become managed by BLM, had no management direction until 1934 when Congress enacted the Taylor Grazing Act. This first attempt to improve range conditions on these lands created local Grazing Advisory Boards to set grazing levels, identified the importance of protecting the land from overgrazing, and established grazing districts and permitting requirements. Inadequacies of this legislation soon became apparent because there was no positive change in range condition and the Grazing Advisory Boards were comprised of ranchers unable to regulate grazing for purposes of conservation (Coggins et al. 1982).

19 Therefore, no improvement in range condition occurred by- management directed by the Taylor Grazing" Act f Coggins and Linderberg-Johnson I3H2'. Enactment of the Federal Land Management Policy Act (FLMPA) in 1376 formally changed responsibility of BLM fr :.-r.i managing land solely for mineral aj cattle production to requiring multiple use for wildlife, recreation, watershed protection, etc., in addition to minera' and livestock (Coggins and Linderberg-Johnson 1982.. Strong opposition to multiple use management on BLM lands by the min: and livestock industries has, however, prevented successful implementation of most provisions and the intent of FLMPA (Coggins 1983). Therefore, in many respects present managemei has not improved the quality of vegetation or watershed stability. This is supported by the identified condition of riparian and wet meadow wetlands as presented in the Current Acreage and Trends section of this report.

It is apparent that livestock utilization ha s a e g raded t he quality and eliminated substantial quantities of r i p a r ian a n d w e meadow wetlands through a y_aj^i^^y__qf mechan isms . The f i r s t resulted from homesteaders not realizing limitati o n s of vegetation productivity and placing more lives toek on t land than it could support. The second resulted, and probab ly continues, to ignore other valid uses such as wa I e rshed , top and wildlife protection. Although legislation ex- ists r e q u i r recognition of these values, the condition of the land i n d i ca t e s that the Federal land management agencies ignore this d i r e c t i o n and largely manage fp_r_the single purpose of lives t o c k production.

The third mechanism considers ecological aspects of southwestern vegetation and its inability to tolerate trampling and tissue removal resulting from livestock grazing. Information gathered from regions naturally occupied by ungulate grazers shows t h a the vegetation in these situations responds positively to grazing. Comparisons between grazed and ungrazed sites in the Serengeti plain of Africa, where the largest concentration of grazing ungulates occurs, show that grazed sites have greater vegetation diversity and higher productivity than ungrazed sites. Vegetation in the Serengeti is apparently adapted to trampling and clipping by its ability to increase its photosynthetic rate when tissue is removed by grazers, and by the energetic relationship between plant root structure and growth, and vegetative growth. These plants are able to retain sufficient root reserves during grazing periods by sustaining adequate leaf area to provide energy required for growth and reproduction (McNaughton 1979). Vegetation and communities of Nevada have not evolved under the influence of grazing and are, therefore, relatively intolerant of trampling and tissue removal. One of the major differences between Nevada and Serengeti vegetation is the response of roots to vegetative removal. Nevada vegetation tolerates a small amount of vegetation removal before it depletes the food reserves in roots that are necessary to maintain viability. Grazing in Nevada is frequently of an intensity that plant vigor is not maintained and death occurs.

20 The natural absence of large grazers (e.g., bison and elk; fror; Nevada Hall 1543, 1961;, in preset t lement times also i n d i c af e s t h a T: t h e r e g i o n was p o n r 1 y suited to g r a - i n g . M c D o n a 1 d ;198i' refers Co the poor quality of forage as the reason why bison did not occupy Nevada even though herds roamed over most of the surrounding area. Free access to Nevada would have permitted bison establishment if forage would not have been limiting. Elk naturally occurred in a small mountainous portion of northeastern:, Nevada prior to recent management which has transplanted them into other mountain ranges where they thrive. The restriction of elk to mountain ranges where they have been introduced attests to 14 »' their inability to cross broad valleys to occupy widely separated; mountain ranges. If V The BLM and USFS follow particular permitting procedures to regulate grazing on public lands. Permits regulate grazing intensity by identifying the season of use and number of animal use months ^AUMs) (an animal grazing an allotment for 1 month represents one animal use month) allowed on a parcel of land termed an allotment. Fees are then assessed against this according to a rate which is derived frvun the formula shown b e 1 o w .

Calculated Fee (CF'. = $1.23 x FVI - 30F1:;?_PI 100

Where:

CF = The Calculated Fee to be charged, which Congress defined as fair market value, which is the estimated economic value of livestock grazing to the user, and where annual increases or decreases in the fee are limited to a plus o r minus 25 percent of the previous year's fee.

$1.23 = The base value established in 1966 through the Western Livestock Grazing Survey.

FVI = The Forage Value Index, an index of annually surveyed private grazing land lease rates, 1964-1968 = 100.

BCPI = The Beef Cattle Price Index, an index of USDA annually reported prices of beef cattle over 500 pounds, 1964-1968 = 100.

PPI = The Public Rangeland Improvement Act Prices Paid Index, indexed prices that producers of livestock pay for selected production items, 1964-1968 = 100.

Determining an appropriate fee for grazing rights has been the subject of intense study by the Departments of the Interior and Agriculture during the past several years.

21 The study was recently completed and the conclusions presented to Congress during February 13J.U" with a recommendation that grazing fees be increased from the $I.33..'AUM rate calculated for 1305 to $4.15/AUM :USDA and U.S. Department of the Interior 1986}. This recommendation has not been implemented and the 1986 fee is retained at $1.3f)/AUM. The impact that increasing these fees to fair market value will have on these wetlands is difficult to determine because the impact would vary between allotments and operators. There is little doubt, however, that grazing pressure would decrease allowing range conditions and wetland conditions to improve. This improvement would result from changes in utilization largely due to a decrease in the incidence of sub-leasing which commonly occurs at the present time. The recent evaluation of grazing fees (U.S. Department of Agriculture and Department of the Interior 1986), as well as a number of other BLM reports, recognize that many ranchers with allotments do not run their own cattle but sub-lease the allotments to other ranchers for values much higher than their AUM cost. With this situation, ranchers paying the government for grazing fees are interested in leasing the land for as much as possible, ana therefore, for utilization by as many cattle as possible, and not in grazing the land at a sustained production level. In essence, the preference rancher actively supports and encourages overgrazing to maximize his profit from sub-leasing- Raising the grazing fees would narrow the discrepancy between the amount being paid by the preference rancher and the amount paid by sub-leasors. This would result in making sub-leasing less financially attractive and encourage the preference rancher to run his own cattle on his allotment. Since he would then be faced with sustaining a yield'from his allotment to support his livelihood he would then be interested in good grazing management practices rather than those causing deterioration.

Maintaining a below fair-market-value grazing fee functions as a subsidy. Although the livestock industry and the Departments of Interior and Agriculture (1986) conclude that any increase in fees would be economically disastrous to the industry, the high incidence of sub-leasing indicates these conclusions are erroneous; if fair market prices were higher than what could be tolerated by tTie industry then sub-leasing would not be common practice. Regardless of the mechanism, wetlands would improve because of decreased grazing, either because economic conditions would decrease the number of ranchers (ergo cattle) or better range management practices would be implemen ted.

Diversion of flowing waters has caused substantial declines of all wetlands with Nevada. Large reclamation projects have decreased inflow into palustrine emergent wetlands causing thousands of acres to dry and become useless. Smaller diversion structures have continually impacted riparian wetlands by capturing the entire discharge of many streams and delivering it to nearby ranches for irrigation. These types of diversions typically have no impoundment and consist of an intake located within a canyon mouth, fortified with concrete and protected from

22 flooding", and a pipe extending" to a nearby ranch. The federal g" 1 ved i r. c ons t r u c t i o n and nia i n t e:i an ee c> f these diversions through several different processes. Many hav^ been c o n p er a t i v e1 y f u n d e d b y t h e U . S . A g r i c u 11 u r a i 3 t a L i 1 i z a t i -. :• n ana Conservation Service ("ASCS:, and most have required permi 11. i n;.>" for either easements of special ur,e from the BLM and/or USF3. The number of projects and the amount of impact they have had on riparian wetlands is unknown because BIOS I were constructed more than 20 years ago and records have been poorly- kept. The Federal land management agencies play a relatively minor role in the affect these projects have on riparian wetlands becviuse they are merely link in the process of construction and p r o vide n o f i :i a n c i a 1 i n c e n t i v e s .

Cost sharing by ASCS differs between Nevada counties but averages 50 percent per project, to a maximum of $3,500 per individual annually. In some counties the cos t s ha r i n g per project may reach 70 percent, depending" on the amount of water a project is anticipated to be saved. The program is designed to encourage maximum utilization of water for agriculture and, therefore, prevent water from remaining in the natural environment. Construction or improvement of diversions is usually quit-» costly because of re-.j u i r erne nt ~, for labor and material. A minimum total cost is estimated by ASCS personnel as 315,000. Conversations with several .--SOS county officials indicated that few diversion projects have been funded in the past 10 years and that few a r" e anticipated in the near future. This lack of activity is attributed to the high project costs. All interviewed ASCS personnel believed that these projects would not be constructed without cost sharing incentives.

The sizable impact of small diversion to riparian wetlands which occurred in the past has apparently slowed because of present day construction costs. This does not mean, however, that their impact on riparian wetlands has decreased; only that their rate of increased impact has declined. The age of existing structures suggests that renovation will become more common and therefore future requests for cost sharing will increase over present levels. Activity may also increase as additional agricultural development increases the demand for water resources. Increased demand for water in many areas of Nevada have been satisfied by development of ground water resources; however, many areas are closed to additional certificates allowing additional ground water depletion. This is likely to increase interest in development of surface water resources that are presently undisturbed by diversion. Therefore, in the long term, small scale diversion construction is anticipated to additionally decrease riparian wetlands.

Herbicide applications are conducted to eliminate woody vegetation unsuitable as cattle forage and thereby expand pasture land to increase livestock productivity. This activity primarily occurs on private lands and has been cooperatively funded through cost sharing from ASCS. Annual practices (i.e., short-term agreements) are subsidized 50 percent and for long-term

23 agreements ASCS pays 55 percent. Spraying has been restricted private lauds primarily because extensive meadows bordering streams is a vegetation community res •:. r i c t ed to valley bottoms where roost private lands are located. Again, it is impossible determine the magnitude of this prcgrair. because ASCS destroys records. However, the ASCS office in Elko provided the information summarized in Table 4 to indicate the recent extent of this program in a small portion of northeastern Nevada.

Table 4. The date, location, and amount of riparian wetlands treated with herbicides during programs subsidized by USDA, Agricultural Stabilization and Conservation Service in Elko County, Nevada.

Ranch Location Acres Year

Rafter Diamond Humboldt. and Mary's River 5000 1976

Hawks and Son Mary's River 150 19RO

Bell Brand Sun Creek 50 10S1

The decreasing activity of this program as shown in Table 4 between 1975 and 19R1 is believed indicative of this herbicide spraying program throughout Nevada. The decline is not due to economic practicalities of the program, but rather to the environmental cost paid in the loss of pasture land that is adjacent to streams during periods of high stream flow. Ranchers are realizing that riparian vegetation protects stream banks from erosion.

The effects to riparian wetlands of road construction, mining, and recreation have not been quantified; however, some resource specialists with the Toiyabe National Forest believe these activities have a significant impact. The magnitude of impacts are anticipated to increase in the future with increases in population and additional mineral exploration. Road construction largely consists of secondary, dirt or gravel roads providing access to mine property. The rugged topography of Nevada increases the impacts of these roads by relegating the easiest routes to canyon bottoms where riparian wetlands are located. These roads are frequently restricted to riparian corridors where they cross streams many times. Riparian wetlands are degraded first during construction then later when high stream flows scour exposed soils and erode remaining vegetation (Cordone and Kelley 1961). Development of mine sites causes similar impacts; however, they are typically more localized than roads.

24 Hoaci construction and mining most y o c c u r pub 1 c 1 ands s i n;: e most I a n as in Nevada a r e p u h lie and the y a e o p en t mineral exploration. The 1372 mini: law gives to Federal land management agencies i n i gards t their responsibilities to f a c L1 i t a t e miner •; 1 explorat i n and development. These directions are, how ever, m e d a t e d by legislated requirements for environmen t a 1 s t ab i 1 t y w h i c h for land reclamation following mining and revere at ion of expose;: soils to decrease erosion. Mining act ivities an road c o n s t r- u c t i o n activities a r e permitted to users b Federaral land management agencies and, therefore, no t m o n i t a r i s u pu n r the Federal government.

R e c r e a t i o n a 1 a cr iv ities are primarily restricted to ; i: ;3 L ic lands in Nevada and m o st i- e c r e a t i o n is concentrated in r i iar ian areas because the wa ter and shade provide pleasant condit ons amidst the arid dese rt. Activities mostly involve camp in; and fishing and m i n i m a 11y a f f e c t existing riparian wetlands, Trampling and e r o s i on are problems in some areas, but the: usually restricted t o 1o c a 1 riparian wetland s i. t e s . Camp'; r o u n u s operated by Federal Ian d management agencies are construe' e d to avoid these types of pr obi ems by not being located within riparian area s and p lac ing trails so they cause minimal \i There are no sub aidi e s n c e n t v e s d e v e 1 o p m recreation faciiities o aeral ands in Nevada.

The major detrimental impact upon palustrine emergent and lacustrine wetlands in Nevada has been caused by Federal irrigation and flood control projects. A list of these projects and their major structural features are presented in Table 5. A discussion of each of these projects and how they have impacted wetlands will follow.

N§wl_ands Proj.ect

The Bureau of Reclamation's Newlands Project provides water from the Truckee and Carson Rivers for irrigation in the Lahontan Valley—primarily the lower Carson River basin near Fallen, Nevada (Figure 3). The irrigated service area has ranged between 57,000 and 67,000 acres over the last 20 years. The area of land determined to have water rights is approximately 73,000 acres, including canals, roads, and buildings (USER 1986). The principal crops produced are alfalfa hay - 70 percent, and irrigated pasture, barley, wheat, and vegetables in descending order (USBE 1986). In 1983, the gross harvested crop value from project lands was over 23.1 million dollars (USBLM 1984g).

25 TabI-- ." . Nevada's Major Federal Projects and Their Features.

(Acres) SeS er r v i c A r e a Project

Nev.7l and s •232,800/61,000 Lake Tahoe Darn Derby Diversion Dam and Truckee Canal Lahontan Dam an;! Reservoir Lateral Canals (312 miles)

Prosser Dam and Reservoir Stampede Barn and Reservoir Marble Bluff Dam and Pyramid Lake Fishway * S u p p i e m e n t * Watasheamu Dam and Reservoir 43,380 * Dressier Diversion Daia and Afterbay * Paiute Dam and Reservoir * Enlargement of Stillwater Point R e s e r v o i r Humbo 1 dt 40,000/30.000 Battle Mountain Water Develop- ment and Collection System Rye Patch Dam and Reservoir

Proposed but never' built due1**' to high cost/benefit ratio.

The Newlands Project was the Nation's first reclamation project created through the 1902 Reclamation Act. The objective was to stimulate settlement of the arid west. Subsidies built into Federal irrigation projects encouraged settlement and have resulted in negative environmental effects on the region (Frederick et al. 1982). The Newlands Project has had a tremendous impact on wetland habitats in western Nevada and it is evident that water subsidies have been involved. A loss of approximately 109,000 acres of wetlands can be attributed to the project.

Traditionally water demands by the project have been high due to low delivery efficiencies, lack of water metering devices, poor enforcement of water decrees, and the lack of financial incentive for efficient use of water. There is no charge for the water based upon quantity of water used. The only charge is that incorporated into water rights certificates assigned to each parcel when the Newlands Project was first established. The price allocated for repayment of these certificates was determined by the water duty, the number of acres, and the original construction cost of the project. The lump sum per year for repayment to the Bureau of Reclamation for these certificates

26 r is $9,0 0 0 p e r year. S o me w at e r payments began wi t h t h e i n i. t i a t i ;;: < ;• f water d ft I i •/ e r i e s a r o : i ;i •. i 1 '.-51 n .1 n d will continue L n t: > the late I9301s ''Howard Hirahara, personal coraniuni ca t ion , USHR, S aor rimer, t o , California. . Using Bureau of Reclamation data cor the number of water-righted irrigated acres in 138.", and the water duty assigned to these acres (USSR 190fi";-, the cost to the farmer' for water averages 4 cents per acre-fooh per year.

The Reclamation Act of 1902 and subsequent amendments p r o v i d e d the basis for below-cost water sales to irrigation. The result of this legislation was repayment of all capital costs, with no interest payments, within 50 years (LeVeen and King 1983, S c h a n z 1386',. T h r o u g h a variety o f p r a c t i c e s , n o n e o f t; h e m sanctioned by Congress, the Bureau of Reclamation has managed to increase the subsidy far beyond the original Congressional intention (LeVeen and King 1985). This is exemplified in the Newlands Project, by the extended repayment period well beyond the 50 years mandated by Congress. The result has been an extremely generous interest subsidy. A 1980 report by the Department of the Interior showed that the difference between actual capital cost and prices charged to i r r i g a t o r s ranged from 57 p e r c e n r to 97 percent of full capital cost for 18 representative Bureau of Reclamation irrigation districts . Schan:< 1986). The capital, cos::: for Newlands Proj^ci water is not known: however, the price farmers pay can be compared to the cost to private sector farmers who pump their water. Although insignificant ground water pumping for irrigation occurs on Newlands Project lands, a c o mp a r i s c n can be made to Mason Valley, approximately 40 mi the southwest where pumping costs are $14.00 per acre-foot 1985). The average cost for pumping in the remainder of the State ranges from $10.00 to $15.00 per acre-foot (Larry Goods on, personal communication, USSCS, Reno, N7evada). This cost may be higher depending upon the efficiency of the pump, the location of the power plant relative to the farm, and the depth of the well.

In addition to the original water certificates two contract.s have been initiated within the past 10 years. The annual installment payments to the Bureau of Reclamation are $61,500.00 (Howard Hirahara personal communication, USER, Sacramento, California). Based upon the number of water-righted irrigated acres in 1985, the charge is $1.07 per acre. As is evident, the payments by the farmer to the Federal government for the privilege to farm this land are extremely low.

Before the establishment of the Newlands Project, the Carson River flowed uninterrupted into Carson Lake, sustaining a ; productive marsh, waters from which then flowed through the Stillwater Slough to the Stillwater Marsh and then to the Carson Sink. Prior to 1970 Carson Sink supported wetlands comprising the Fallen National Wildlife Refuge. On completion of Lahontan Dam in 1915 and the subsequent development within the Newlands Project, the quantity and pattern of water inflow to these wetlands was changed considerably. Spring and late summer runoff from the Carson River and portions of the Truckee River are now stored in Lahontan Reservoir for release during the irrigation

27 season in support of agriculture .Pyramid Lake Task Force 1971;. Although Carson River discharge to the project is supplemented by the Truckee River, the quantity, quality, and t i m i n g of fiews to «.•.- i 1 ••\ (i c* unequa1 h o r : a 1 t i ai e s and a p p r o x i m a t e 109,000 acres have been 1

Subsequent to the deve1 u p ra e n t of the Me w 1 a n d s Project , Stillwater, Canvasback Gun Club (adjacent to Stillwater}, Carson Lake, and Carson Sink began receiving agricultural drain water discharged from the Truckee-Carson Irrigation District. With the exception of the Canvasback Gun Club these Wetlands have no established water rights. They must rely on drain water ol v a r y i n g qu a n t i t i e s a n d q u ait 1 y and operational spills fr >m Lahontan Reservoir. During low flow periods, water supply to the wetlands is comprised mosti y of agricultural drain water containing proportionately- higher total dissolved solids con c e n t r a t i o n s . During periods of high flows, water spilled from Lahontan Reservoir dilutes agriculture drainage water.

The regulated portions of Stillwater are situated b e t w e e! agricultural lands and the Carson Sink. Prior to development the Newlands Project water passed through the marshes and int.; the sink where most of the sodium and calcium salts were deposited. As water f 1 o w s decreased, less water .T. a d e its w a y the sink and more salts were deposited in the upstream marsh areas (Pyramid Lake Task Force 1971). Adequate supplies of w are critical for maintaining salinities below the tolerance limits .for plant production. An example of the consequences w e r e demonstrated during the spring 1963 when water supplies t Stillwater were insufficient to reduce salinities. Large stairuls of alkali bulrush were impacted. High salinities had prevent ed seeds from germinating and killed most young plants. The bulr u s h is important nesting habitat for redheads and provides enormous amounts of food for migrating waterfowl (Pyramid Lake Task Fo >' Q r-* 1971); hence, during drought years when spills do not provide the water necessary for dilution, both quantity and quality of habitat is reduced.

In 1967 the Secretary of the Interior instituted operating criteria for the Newlands Project designed to increase Truckee River flows reaching Pyramid Lake. These operating criteria eliminated flows to generate electric power below Lahontan Dam during the winter months (U.S. Department of the Interior 1969). As a result approximately 12,000 acre-feet of the highest quality water for Lahontan Valley wetlands was eliminated (Pyramid Lake Task Force 1971). This is a more significant loss in dry years when there are no operational spills from Lahontan Reservoir. Subsequently, the perennial Carson Sink wetlands (including Fallen National Wildlife Refuge) were lost and the quantity and quality of the wetlands at Stillwater and Carson Lake were significantly reduced (Wildlife Society 1980).

When diversions for the Newlands Project began, inflow to Pyramid Lake from the Truckee River decreased. This river provided the majority of natural inflow to Pyramid Lake. The

28 ke r, urfar. s fluctuated around a stable level only because of nign '.%• a t e r v ears w hen a r g e s n o w m e 1 '. f th .: r ea L eu I h e T r u c ]•; e e R 1 v e r - d i v e rs i o n s , a v e r a g i n £ 5 0i percent of river f I O W S , COED mat ion with d r o u g h t c o n d it i. o n s d Pyramid Lake to droo SO feet years (Harris 1970,. With the permanent drop in Pyramid Lake t c o n n ection to Winnemucca Lake, via Mud Slough., was cut. off. B v the e arly 1930s, the river was flowing only into Pyramid Lake, and W innimuc-'a Lake was dry by 1938. The level of Pyramid Lake con t i nued to decline, reaching a 100-year low in 1967 fBrown et ai. 1906;. The lake level has recovered somewhat due to above- a v erage river flows during the 1970s and early 1580s (Brown et •a 1 1 986 ' F igure :~ ) .

As the Pyramid Lake level declined a delta at the mouth the Truckee River developed. This made spawning access to the Truckee River by Lahontan cutthroat trout (Trout.! difficult t impossible by 1929 (Suniner 1938, 1940',. In addition, Derby D posed a physical barrier to upstream fish migration. Historically the Trout spawning run ascended as far as Lake Tahoe. By the early 19-10's the Trout was extinct in Pyramid Lakt (La Rivers 19G2). Restocking efforts by the Nevada Department of

Wildlife the 1950s >es tab 1 i t h e S .ujnuaJJL__Like 1 f '• ; - ; Trout which is closely related to the P r e s i a n! i t r.v o Indian hatcheries stock b< ;veen and two million Trout per year.

Concurrent to the demise of the Trout, reduced river discharges have also hampered the upstream spawning movement of the cui-ui and degraded spawning beds (USFWS 1970.. Higher wate; temperatures and insufficient flows to flush detrimental silt from spawning gravels contribute to poor egg survival. The Pyramid Lake Paiute Tribe currently releases up to 10 million hatchery raised cui-ui per year into the lake.

As a result of the decline in the populations of these fish and the poor natural recruitment rate, the Lahontan cutthroat trout is federally classified as threatened and the cui-ui classified as endangered.

W§§>hoe Project

Reclamation's Washoe Project was designed to improve the regulation of runoff of the Truckee and Carson River systems. The increased beneficial use of water through implementation of all project features was to provide supplemental irrigation water supplies and drainage for presently irrigated lands, water for municipal and industrial use, aid in restoring the Pyramid Lake fishery and other measures for fish and wildlife enhancement, flood protection, hydro-electric power, and recreation benefits.

The major project features are listed in Table 5. Project features designed for fish and wildlife enhancement include Stampede Dam and Reservoir, Marble Bluff Dam, Pyramid Lake

29 '

3880

UJ 111 u. 3840

UJ _J UJ

3800

1860 1900 1940 1980 YEAR

Figure 5. Water surface elevation of Pyramid Lake 1867-1986. (Broken line indicates incomplete records).

30 ishway, arid Stillwater Wildlife Management Area improvement facilities (USSR 1376c) .

The facilities at Stillwatei- were never built. They would have improved the water supply for waterfowl habit a1- by increasing the capacity of the e:•:is t ing Stillwat er ?c in L Reservoir by about 6,000 acre-feet and by constructing Paiute Dam and Reservoir with a capacity of about 4,000 acre-feet CUSBR 1976a~>. This increased storage capacity would have taken advantage of some spills from Lahontan Reservoir that flow to the Carson Sink where they are nearly useless for waterfowl habitat. Conveyance facilities were planned to improve the distribution and movement of drain and spill waters to Stillwater from the two r e s e r v o i r s .

Huinbo]_dt Project

The Humboldt Project is located on the lower flood plains of the Humboldt River in Northwestern Nevada. The Humboldt is the longest river contained entirely within the boundaries of one state, approximately 300 miles. The river and its tributaries are t he sole source of water for the HumbolJt Pro.je':r.

Project aspects include Rye Patch Dani, which is located on, and impounds the flow of the Humboldt River for later use in irrigating lands in the area, and the acquisition of lands ana water rights upstream in the Rattle Mountain area, as well as a n y construction and rehabilitation needed to transport the water to the project lands (Figure 4). The Humboldt Project irrigates approximately 30,000 acres with an average annual water diversion below Rye Patch Dam of 108,050 acre feet (Nevada State Engineers Office 1974). Of that, 32 percent reaches the Humboldt Sink wetlands through overflow and drainage (USFWS 1981a.. The remaining 74,000 is lost through evapotranspiration. Also, approximately 55,000 acre feet of water are lost to evaporation from Rye Patch Reservoir each year. Total water loss due to the Humboldt Project equals 129,000 acre feet, which would maintain 25,800 acres of wetlands for 1 year. Also, since the Sink's water supply comes mainly from return flow of irrigated lands, we assume that water quality was better and that the wetlands were both larger and more productive prior to the irrigation project.

FUTURE VULNERABILITY

Ei2§li§0 §D<* Wet Meadow Wetlands

The stability and persistence of these wetlands in the desert environment is strictly dependent on the reliable presence of water and the stability of watersheds. These wetlands, as will all wetlands, perish without water, and without watershed stability they are eliminated by scouring floods. Many Federal programs subsidize the degradation of these wetlands and cause

31 them to dry or become unstable. With continuation of these programs there is little reason to believe that conditions will improve. Both of these wetlands are presently unstable and in such degraded condition that they are extremely vulnerable to continued elimination. Changes in the financial attractiveness of perturbating programs is believed to be the best method to quickly decrease vulnerability because it will quickly change the focus from maximal production of cattle and crops to maintenance agriculture that is implemented to insure continued productivity from the land. P§lu§£rine l5§Hgent and Lacustrine Wetlands Newlands Project Several factors will influence the future demand for water by the Newlands Project, and thus impact wetlands in Lahontan Valley and elevation of Pyramid Lake. These factors include proposed diversion criteria for the Newlands Project (Operating Criteria and Procedures, "Procedures"),the Rehabilitation and Betterment Program proposed by the Bureau of Reclamation, implementation of the Fallon Indian Reservation Irrigation Project, management action regarding dust control at the Fallon Naval Air Station, and a variety of water saving measures that may or may not be feasible. I. Operating Criteria and Procedures The Newlands Project has been involved in controversy resulting from intense competition for the limited water supply of the Truckee and Carson Rivers. In 1964 the Secretary of the Interior formed a task force to study and report on methods to .resolve the controversies. In 1967 the Interior Department issued regulations governing the use of water on the Newlands Project lands (Pyramid Lake Task Force 1971). The primary purpose of the detailed Procedures was to limit diversions by the irrigation district within decreed rights, thereby making additional water available to Pyramid Lake; however, the Procedures have not been successful in preventing diversions in excess of applicable water decrees due to the design of the -Procedures (Pyramid Lake Pauite Tribe of Indians v. Morton, 1972) and deliberate violations of the Procedures by the District (Truckee-Carspn Irrigation District v. Secretary of the Interior 1983). It should be noted that there is some disagreement as to the applicability of these court cases. •'" Because of v.the District's violation of Procedures, -the United States.and the District:have entered into a temporary agreement '^whereby the District\has been permitted to continue operation of ,;the,project under interim Procedures . Reclamation is developing; hew lorig-,term Procedures starting in 1987 that will replace the'interim Procedures in place since 1984. These Procedures are likely to result in lower diversions from the Truckee River and reduced flows to Newlands Project lands. If this occurs less water would reach the wetlands and would include

32 a larger proportion of irrigation return water of lower quality. This would influence the extent and quality of wetland habitat. Along with reductions in acreage of wetland plant communities, changes in the species composition of these communities toward more salt tolerant species may be expected. These species tend to be of lesser nutritional value to wildlife. In some instances wetland units would continue to support wetland vegetation only in wet years. Currently Reclamation refuses to acknowledge and adhere to the requirements under the Fish and Wildlife Coordination Act, one of which is to provide mitigation measures for fish and wildlife habitat losses (Bob Hallock, personal communication, USFWS, Reno, Nevada). This is inconsistent because in the 1977 U.S. Bureau of Indian Affairs Draft Environmental Impact Statement on the proposed Procedures, a mitigation plan was offered that would offset wildlife losses in the Lahontan Valley wetlands by 36 percent (USBIA 1977). Presently no such plans are being offered and the outcome to wetlands could be devastating. If Procedures are implemented which result in Truckee River flows inadequate to provide sufficient spawning conditions and a fairly stable Pyramid Lake level, the threatened and endangered fish habitat will be further degraded. Increasing alkalinity is a problem associated with Newlands Project water diversions. Between 1933 and 1979 Pyramid Lake's total dissolved solids rose 32 percent from about 3,750 mg/L to 5,250 mg/L (Galat et al. 1981). Before the Newlands Project the total dissolved solids levels were reported by the U.S. Geological Survey to be 3,275 mg/L and 3,486 mg/L in 1867 and 1882, respectively (Taylor 1972). Alkalinity is a very important factor in the growth and survival of cutthroat trout and cui-ui. Studies have indicated that total dissolved solids levels of 5,897 mg/L have caused kidney degeneration in Lahontan cutthroat trout (Lockheed Science Laboratories 1982). Studies with juvenile cui-ui indicate that the highest percent mortality (23.3 percent) occurred at 9,751 mg/L and lowest mortality (15 percent) at 5,255 mg/L (Lockheed Science Laboratories 1982). As flow into Pyramid Lake decreases and evaporation continues, alkalinities will persist in stressing fish.

N Stabilization of Pyramid Lake is also important to maintain the geographical integrity of Anaho Island and protect the island pelican rookery by maintaining a physical water barrier against predators (Pyramid Lake Task.Force 1971). II,. Rehabilitation and Betterment The Rehabilitation and Betterment Program proposed by Reclamation will provide for the optimum use of water under all conditions by increasing efficiencies throughout the system! Such a program would include the lining of canals and laterals, motorizing and automating regulating structures, installation of measuring devices to improve water regulation, drain modification, and repair and upgrading of diversion dams. This

33 r <; jr ".si v.oul.l result In projected water savings of about 48,000 acre-f-=et annually 'USSR 1986} . This water savings would come at the expense of '.vet Ian da which, at present, indirectly receive this water. Five acre-fee t,-'acre/year of water is required to main t :-i in one acre of wetland vegetation fUSFWS 19R!a:. Thus 9,fi00 acres of wetlands would be lost.

III. Water Deliveries

The number of irrigated acres within the .Yewlar.ds Project area may change in the future. Currently, the Fallon Naval Air- Station has approximately 2,934 water-righted acres of which approximately 2,200 acres were irrigated in 1305 (US3R 19Sfi). The Fallon Indian Reservation has 5,440 water-righted acres of which approximately 2,210 acres were irrigated in 1985 (USER 1986). These two groups are exploring alternatives to change the amount of irrigated acreage.

The Fallon Naval Air Station leases its water-righted lands for alfalfa production as a means of dust control. In 1984 the Pyramid Lake Paiute Tribe of Indians issued a Notice of Intent to file suit against the Navy alleging that their irrigation procedures were in violation of the Endangered Species Act, the National Environmental Policy Act, and that the endangered cui-ui and threatened Lahontar: cutthroat trout were in jeopardy due t j the Navy's practices. Beginning in 1985, as a result of an out of court settlement, the Navy agreed to reduce water use or; the leased land by 25 percent and develop a water conservation plan. A suggested long-terra plan for dust control could b-c achieved with salt grass using only domestic wastewater frc::i the air- station. This would eliminate an annual average diversion of 17,500 acre-feet from the Truckee River and reduce shortages to the remaining agriculture in the project area (USBR 1986). As a result approximately 550 acres of wetlands could be lost.

The Fallon Indian Reservation may increase the number of acres in production to the full water-righted amount of 5,440 acres. The Reservation has been receiving approximately 16,200 acre-feet annually although only about 6,100 acre-feet of this water is used to irrigate the land presently in preduction. The excess water has traditionally passed through the Reservation and into Stillwater.

If the agricultural area is increased on th- Reservation, water deliveries will be 19,000 acre-feet per year, the full water right. Much of this increased water demand would be fulfilled by increasing Truckee River diversions, leaving up to 14,700 acre-feet less water for Pyramid Lake (USFWS 1985b). The increase in crop production would result in less water for Stillwater and a subsequent reduction of about 950 acres of wet land.

There are a variety of measures that could reduce the water delivery requirement of the Newlands Project and thus the

34 allowable diversion at Derby Dam. These* measures and associated w d t e r savings are as folio w s :

1. Increase efficiencies by an av-rag'e of 9 percent through improved monitoring and water management--30,000 acre-fe^t/year.

2. Adjust allowable diversion for non-alfalfa crops, sub irrigated, drainwater irrigated, ground water irrigated, and non-water righted irrigated acr eage--30 , 000 acre-feet -'yea r .

3. Adjust allowable diversion by 5 percent for non- irrig-ited acreage 'roads, canals, buildings, etc.' -18,000 acre- feet/year .

4. Implement an irrigation season from ;! .15-11 / 1 5--29 , 000 a c r e-f e e t/y ear.

5. Disallow diversion t o w at •'-. r-r i g h t a t r a n s f e r a pp1i c a11o n s approved by the State Engineer--8,000 acre-feet/year.

The implementation of these measures will depend upon p i- i v a t, e , State, an d Federal cooperation. If all of t h e s e are implemented appro:: Lma;. ely 115,000 acre--fee!: per year of water would be saved. This water would no longer be available to w e 11 a n d s a s r e t u r n \\ t e r of spills and c o u i d result in I o s s o f the majority of existing wetlands in L ah a atari Valley. Implementation of these measures would translate into water savings for the T r u c k e e and Carson Ri v e r s. Reduced diversions from the Truckee River would help maintain Pyramid Lake at a stable level needed to prevent the decline of the fishery and provide essential spawning flows. d£li^ylii:l§i Stabilization and Conservation Service

The ASCS provides a cost sharing program to farmers for irrigation water conservation on land currently under irrigation. The primary incentive for farmers to participate in these programs is the savings of time and labor.

In some parts of the United States, ASCS activities facilitate the drainage of wetlands for conversion to agricultural lands. In the case of the Newlands Project, Service subsidies have not had a measurable impact upon wetlands and probably will not in the future. ASCS data show that although water conservation practices have increased efficiencies by up to 28 percent on Newlands Project lands, depending upon the individual farm and practice involved, the average irrigation water savings is zero (USASCS 1984-1986). This is because the farmers do not want to reveal the amount of water that has been, and continues to be over diverted and because over diversion is still occurring. If water management activities result in less water to Newlands Project lands, each farmer will receive only

35 .he water entitled to him. I n this c;ise more farmers may request Service assistance to utilise their water more efficient!y but the decrease in drainage water to the wetlands will he due to water management activities not ASCS practices.

Humboldt. Project

In 1387 Rye Patch Dam will be studied by the Bureau of Reclamation under a Safety of Dams Program. Recommendations could include: Raising embankments, enlarging the spillway, building a new dam, or most critically, changing operating criteria. These possibilities could allow more land to be put into agricultural production. There are approximately 40,000 acres of irrigable project land of which an average of 30,000 are presently irrigated each year (USER 1976b;, leaving 10,000 acres for potential development.

Most crops receive about 4 aere-feet per acre annually (Nevada State Engineers Office 1974). If the "extra" 10,000 acres are irrigated an additional 27,200 acre-feet of water will be consumed (assuming 32 percent returned to the wetlands). This 27,200 acre-feet loss means wetland loss of 5,440 acres, with proportional increases in sal', concentration. Sorae portions of the remaining wetlands would no longer support aquatic vegetation in dry years.

RECOMMENDATIONS

BiE§i:i§D 2yd Wet Meadow Wetlands

Livestock Utilization

Many of the existing laws and regulations include strong provision intended to guide multiple use of public lands. However, the utility of many of the guidelines is severely minimized because they are not followed by the land management agencies, and lands are typically dedicated to single uses. Therefore, stronger, definitive requirements are necessary to direct management affecting riparian and wet meadow wetlands. This goal may be facilitated or accomplished by requiring implementation of the following programs.

1. Revise grazing allotment plans so they recognize the importance of these wetlands, and that they accordingly adjust livestock utilization by manipulating livestock use levels, fencing sensitive areas, developing off-wetland watering sites or altering seasons of use, etc. These plans should concomitantly require that these wetlands be improved then maintained in maximal potential conditions within the next 10 years.

2. Raising grazing fees to fair market value which is anticipated to decrease sub-leasing and make the leasee more responsible for environmental conditions.

36 3. Develop a program to determine the compliance of -1 p .I ,-f >"i rp t^t»i t ' * 1 »•* '*" ' S 1 -5l t. *"i tl DliK"OO~t~lc' " O EL 1. S .

Agricultural Stabilization and Conservation Services Activities

1. Prohibit cost sharing for herbicide application and diversion construction that will degrade the quality of riparian wetlands.

Federal I ;->. n d M a n a g e m e n t A g e :; c y p e r r.i i '•. t i t: g

1. Require permits to recognize the importance of these w e t 1 a n d a a n c! t o i r. c 1 u d e s t i p u 1 a t i o n s t h a t w ill p r o t e c r a n d enhance remaining riparian and wet meadow wetlands.

Newlands Project

1. Implement water management, techniques i ncl -id i. ng Operating Criteria and Procedures, Rehabilitation and Betterment. and other water-saving programs to decrease delivery requirements of the N e w1 a n d s Pr o je c t and save water in the T r u c k e e and Carson R i v e r s .

2. Establish a single water operations center to coordinate all orders for water delivered to individual head gates.

3. Establish a water pricing system based on quantity of water delivered to the head gates that provides financial incentive for economical and efficient use of water.

Mitigate loss of wetlands by:

1. Applying water saved from the Carson River directly to Stillwater and Carson Lake. This will maintain the wetlands and/^^ improve the quality by reducing salinities and preventing the pickup of contaiminants, via agricultural land, enroute to the ^ wetlands .

2. Purchase water rights on lands in the Lahontan Valley for transfer to the wetlands.

3. Design and construction of facilities and associated delivery systems that would take advantage of excess water during high flow years through capture and delivery to the wetlands.

Washoe Project

Construct Paiute Dam and Reservoir and expand capacity of the existing Stillwater Point Reservoir. These facilities would

37 a 1 1 o v,' orage of spill water from Laliontan Reservoir and distribution to the wetlands in L aho n ta n Valley.

Hurabol.dt Project

Should any change in operating criteria be proposed, assurances should be provided to maintain existing conditions in the Humbold'. Sink for wildlife and to replace unanticipated water losses to the wetlands. Water should be delivered in a manner that will a11ow no net increase in salt concentration and that will duplicate present, conditions by flushing Upper Humboldt Lake seven times out of every 2-~ years.

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42 •M

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