ENVIRONMENTAL IMPACT STATEM ENT

NEW M ELONES LAKE

STA N ISLA U S, RIVER,

PREPARED BY

U S. ARMY ENGINEER DISTRICT, SACRAMENTO, CALIFORNIA

M AY 1 9 7 2 ENVIRONMENTAL IMPACT STATEMENT

NEW MELONES LAKE , CALIFORNIA

Prepared by U. S. ARM! ENGINEER DISTRICT, SACRAMENTO, CALIFORNIA May 1972 SUMMARY

New Melones Lake, Stanislaus River Basin, California

( ) Draft (X) Final Environmental Statement

Responsible Office: U.S. Army Engineer District, Sacramento, California

1. Name of Action; (X) Administrative ( ) Legislative

2. Description of Action: New Melon2s Lake project consists of a 625-foot high across the Stanislaus River to impound up to 2,400,000 acre-feet of water. The Corps of Engineers will maintain the Stanislaus River below the dam to a capacity of 8,000 cubic feet per second and provide for the protection of fish and wildlife resources. Access roads to the dam area, resident engineer facilities, downstream public overlook and safety scaling of the damsite have been completed. Currently, construction of the diversion and outlet tunnel is underway and is scheduled for com­ pletion in August 1973. The construction contract for the dam and spill­ way is scheduled to be awarded in the fall of 1972. To construct the dam, about 16,000,000 cubic yards of material will be excavated from the spillway and adjacent borrow areas. Additional work will include road and utility relocations, powerhouse, switchyard, surge tank, clearing and initial recreation facility construction. When completed the project will be integrated with the and will be operated by the Bureau of Reclamation. The Central Valley Project is cribed in appendix C.

3. a. Environmental Impacts: Flood protection will be provided for existing and potential agricultural lands and suburban areas of several communities. Other project benefits are'general recreation, conservation yield, hydroelectric power generation, water quality control flows and fish and wildlife. Salmon and other anadromous species will be enhanced in the downstream areas. About 10,700 acres of land, much of which is used by wildlife, will be inundated along with 16 miles of river. Existing Melones Dam and Reservoir will be inundated.

b. Adverse Environmental Effects: The Stanislaus River reach that „ is presently used by whitewater boating enthusiasts will be inundated. There will be a net loss in wildlife population even though establishment of a wildlife management area and wildlife improvement features will partially mitigate the loss. A number of caves and archeological sites will be inundated. Project benefits will induce development in the region resulting in further loss of natural resources. Project construc­ tion and periodic drawdown of the reservoir will cause some scarring of the landscape. 4. Alternatives; Smaller reservoir; larger reservoir; reservoir at different sites; channel and levee improvement; flood plain management; and no action.

5. Comments Received:

Environmental Protection Agency Sierra Club - Yokut Wilderness Department of Interior Group Department of Commerce Sierra Club - National Director Forest Service Audubon Society Soil Conservation Service National Speleological Society State of California Environmental Defense Fund City of Modesto The Wildlife Society Calaveras County Touring Association South San Joaquin and Oakdale Wilderness World Irrigation Districts

6. Draft statement to CEQ 15 March 1972. Environmental Statement New Melones Project Stanislaus River, California

TABLE OF CONTENTS

Paragraph Subject Page

SECTION I - PROJECT DESCRIPTION

1 Authorization and current status of project 1 2 Location 1 3 Dam and reservoir data 1 4 Reservoir operation 2 5 Land requirements 4 6 Relocations 5 7 Recreation 5 8 Lake area clearing 6 9 Lower Stanislaus River 6 10 Basis of determining cost and benefits 8 11 Summary of cost and benefits 10

SECTION II - ENVIRONMENTAL SETTING WITHOUT THE PROJECT

12 General description of Stanislaus River Basin 12 13 Climate 12 14 Streamflow 13 15 Flood potential 15 16 Water quality^ 15 17 Anadromous fish 18 18 Resident fisheries 20 19 Vegetation 20 20 Wildlife 22 21 History and archeology 24 22 Geological features and groundwater 26 23 Recreation resources 27 24 Land resources and uses 28 25 Socio-economic conditions 29 Paragraph Subject Page

SECTION III - ENVIRONMENTAL IMPACT OF THE PROPOSED ACTIONS

26 Effect on hydrology 31 27 Effect on recreation 36 28 Effect on historical and archeological features AO 29 Effect on geology and ground water A1 30 Effect on water quality ^"'42 31 Effect on fisheries 53 32 Effect on land use 59 33 Effect on wildlife 63 34 Effect of project construction and activities 66 35 Visual effect of project 68

SECTION IV - ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT BE AVOIDED

36 Whitewater boating loss 71 37 Historic, archeological, and geological loss 71 38 Scenic value losses 71 39 Water quality reduction 71 40 Wildlife and wildlife habitat losses 71

SECTION V - ALTERNATIVES

41 Alternative reservoir sites 73 42 Alternative reservoir sizes at the New Melones site 74 43 Alternatives to constructing a reservoir 76 44 Alternatives to the planned operation 77

SECTION VI - RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF THE ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY

45 Long-term productivity 79 46 Short-term effects 80 TABLE OF CONTENTS (Cont'd)

Paragraph Subject Page

SECTION VII - IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES SHOULD THE PROJECT BE CONTINUED

47 Irreversible and irretrievable commitments 81

SECTION VIII - COORDINATION WITH OTHERS

48 Public participation 82 49 Government agencies 83 50 Citizen groups and others 84 51 Unreconciled conflicts 84

LIST OF TABLES

Table 1 Reservoir Data 2 Table 2 Land Requirements for New Melones Lake 4 Table 3 Average Annual Benefits 11 Table 4 Air Temperature at Sonora, California 12 Table 5 Average River Flows 14 Table 6 Surface and Ground Water Quality in the Stan­ islaus River Basin 16 Table 7 Annual Estimates of King Salmon Migrating up the Stanislaus River 18 Table 8 Preliminary Estimates of Stanislaus River Flows with New Melones in Operation and All New Conservation Yield Diverted Above Knights Ferry 32 Table 9 reliminary Estimates of Stanislaus River Flows with New Melones in Operation and with no Diversion of New Conservation Yield from the Stanislaus River 33 Table 10 Existing Recreational Use of Stanislaus River Between Melones Reservoir and Camp Nine 36 Table 11 Estimate of Recreation Use Pattern at New Melones Lake 38 Table 12 Temperature and Dissolved Oxygen Relationships for Stanislaus River Below Goodwin Dam 44 TABLE OF CONTENTS (Cont'd)

Subject Page

LIST OF TABLES (Cont’d)

i Table 13 Estimated Annual Draft on Storage for Water Quality Control 45 Table 14 Minimum Flows in Stanislaus River for Fish 54 Table 15 Predicted Temperatures for Stanislaus River Downstream from Goodwin Dam 56 Table 16 Peoria Mountain Wildlife Management Area - Cover Type 65

LIST OF APPENDICES

Appendix A Comments and Responses Appendix B References Cited Appendix C Description of Central Valley Project, California

LIST OF ATTACHMENTS

Attachment A - Photographs

Photo 1 Existing Melones Reservoir Photo 2 Access road to Tuttletown area Photo 3 Tuttletown area Photo 4 Mark Twain area Photo 5 Stanislaus River, downstream, near Riverbank Photo 6 Natural Bridge, Coyote Creek arm hoto 7 Stanislaus River, whitewater area Photo 8 Stanislaus River above Camp Nine

Attachment B - Charts

Chart 1 General map of basin Chart 2 General recreation plan Chart 3 nvironmental inventory Chart 4 Temperature predictions TABLE OF CONTENTS (Cont'd)

Subject

LIST OF ATTACHMENTS (Cont’d)

Attachment C - Correspondence Received

Environmental Protection Agency U. S. Department of Interior U. S. Forest Service Soil Conservation Service Department of Commerce City of Modesto Calaveras County South San Joaquin and Oakdale Irrigation Districts Environmental Defense Fund Sierra Club - Yokut Wilderness Group Sierra Club - National Office Audubon Society National Speleological Society Wildlife Society American River Touring Association Wilderness World State of California Environmental Defense Fund, et. al. (complaint) ENVIRONMENTAL IMPACT STATEMENT

NEW MELONES LAKE STANISLAUS RIVER, CALIFORNIA

SECTION I - PROJECT DESCRIPTION

1. Authorization tnd current status of project. - The New Melones Lake project on Stanislaus River, California, was authorized by the Flood Control Act of 22 December 1944, substantially in accordance with the recommendations of the Chief of Engineers in Flood Control Committee Document No. 2, 78th Congress, Second Session. That authorization was subsequently modified by the 1962 Flood Control Act (Public Law 87-874). Feasibility and project fomulation information are described in detail in the survey report (1) and an overall description of advanced planning and design information is presented in the general design memorandum (2), both prepared by the Sacramento District. Construction of the project was initiated in July 1966 with arard of a contract for construction ofaccess roads, initial resident engineer facilities, and the downstream public overlook area. This work vas completed in January 1968. By subsequent contracts, safety scaling of the damsite has been completed, the resident engineer's office has been expanded and public use facili­ ties have been provided at the downstream overlook. A contract for construction of the diversion and outlet works tunnel was swarded in June 1970. This work is currently underway and is scheduled for comple- tion in August 1973. The construction contract for the dam and spillway is scheduled to be awarded in the fall ot iv/^- Completion of the project is presently scheduled for June 1978 and is premised upon adequate funding. Prior to the project going into operation an environmental impact statement covering project operation including the use of the new water yield will be prepared by the U. S. Bureau of Reclamation. Since final decisions have not been made on t-hp nppi-aH nn, this state­ ment addresses the subject in a general way only and in terms of remain­ ing alternatives.

2. Location. - The dam is to be located on the Stanislaus River about 60 river miles upstream from the confluence with the . The Stanislaus River forms the boundary between Calaveras and Tuolumne Counties in the Mother Lode foothill region of Central California. will be constructed about 3/4 of a mile downstream from existing Melones Dam, which is owned and operated jointly by the Oakdale and South San Joaquin Irrigation Districts.

3. Dam and reservoir data. - New Melones Dam will be a 625 foot high earth and rockfill structure with a crest elevation of 1,135.5 feet. It will span 1,560 feet between the walls of the canyon and contain 16 million yards of embankment material. Pertinent data on New Melones Lake project is shown in table 1.

NOTE: Numbers which appear in parentheses refer to the numbered list of references cited, included in Appendix B to this statement. Gross Pool

Capacity 2,400,000 acre-feet Surface area 12,500 acres Shoreline 100 miles Elevation 1,088 feet Frequency of filling to An average of gross pool less than once in 25 years

Average Recreation Pool (average pool during recreation season: May-August)

Capacity 1,612,000 acre-feet Surface area 9,705 acres Elevation 1,021 feet

Inactive Pool

Capacity 310,000 acre-feet Surface area 3,320 acres Elevation 808 feet Frequency of occurrence An average of less than once in 25 years

The flood control pool is between elevation 1048 and 1088 feet and on the average will be reached two out of three years.

4. Reservoir operation. - The recommendations of the Chief of Engineers and the authorizing act provide for the operation of the completed project as an integral part of the Central Valley Project. The primary objective of the Central Valley Project is to transfer water from areas of surplus to areas of deficiency. As a result, important agricultural production increases have been realized in the Central Valley of California. The Central Valley Project is described in appendix C. The authorizing act also provides . . . "That before initiating any diversions of water from the Stanislaus River Basin in connection with the operation of the Central Valley Project, the Secretary of the Interior shall determine the quantity of water required to satisfy all existing and anticipated future needs within that basin and the diversions shall at all times be subordinate to the quantities so determined." (4) The remaining water conserved by the New Melones Lake project is presently planned for diversion to the Central Valley service areas. One potential place for such use is the east side of the where a large demand exists for addi- tional water for lands now under irrigation. Studies made by the Bureau of Reclamation for the Initial Phase East Side Division indicate that over 85 percent of the irrigation service contemplated, which exceeds one million acre-feet,|would be a supplemental supply for already developed irrigated lands. This additional water would assist in part in alleviating the major overdraft of groundwater resources in the area, new estimated at over one million acre-feet annually.

Less than 13 percent of the conservation yield is anticipated to be used for irrigation of undeveloped land. Probably less than 10 percent of the land to receive supplemental service is located north of San Joaquin River in Stanislaus, Merced and Madera Counties (5).

If there should be an interim period of time in which facilities were not yet available to serve the east side area, the yield of New Melones Reservoir could be integrated with that from other CVP to effectively meet the demands of other service areas either directly or indirectly, such as Folsom South, Delta-Mendota, San Luis, San Felipe, Contra Costa, and the Sacramento-San Joaquin Delta including the Bureau's share of protecting and enhancing the water quality in the Delta (6).

Up to 70,000 acre-feet per year of conservation yield will be used to meet established water quality criteria on the Stanislaus and San Joaquin Rivers. Criteria and annual draft on storage are detailed in paragraph 30.

In addition to the conservation yield, the project will provide minimum releases for the downstream fishery in accordance with the Bureau of Sport Fisheries and Wildlife schedule (3) of 98,000 acre-feet during a normal year and 69,000 acre-feet djring a dry year. A table showing the minimum flows and the inpact on the fishery is discussed in paragraph 31. Water released for various purposes will be utilized to produce electricity. This is discussed in paragraph 26.

The water levels in the reservoir will vary depending on cycles of dry or wet years, but in general will rise due to runoff from late winter rains and spring snowmelt, reaching its highest pool about May and June and will recede due to combination of water use requirements, reaching its lowest point after mid-Septenfcer.

The flood control storage space of 450,000 acre-feet will range about 40 vertical feet from elevation 1,048 feet to gross pool at 1,088 feet. This space will be made available prior to the rain flood season beginning in Noveriber. Necessary releases to provide this storage space would be made before 1 November.

Storage space above elevation 1,048 feet would be allowed to refill beginning about mid-March, depending on predictions of inflows from the sncwpack in the watershed. During the recreation season, May to August, the average pool level would be at about the 1,020 foot elevation. Below elevation 808 feet, the 310,000 acre-foot inactive pool is reserved for the pcwerplant minimum head, reservoir fishery preservation, and sedimentation. Inactive pool would be reached on the average of les3 than once in 25 years.

Considerable operational information equipment will be installed and utilized. A recording pool gage capable of recording pool elevations to the nearest 0.01 foot over the operation range of reservoir stage, a Class A evaporation station, and radio reporting gages for rain, snow and tenperature will be installed. Sediment deposits in the reservoir will be measured by means of a range system involving a total of five sediment range stations; three in the upper end of the reservoir, one near Parrott's Ferry Bridge and one in the Angel's Creek arm of the reservoir. A water temperature recorder will be installed at the power-­ house to measure and record outflow temperature.

5*.— -Lard -requirements. - The New Melones project will require about ( 25,059 acres of lan2f)as shown in table 2.

TABLE 2 - LAND REQUIREMENTS FOR NEW MELONES LAKE

Oakdale Irrigation District lands 3,614 acres U. S. Bureau of Land Management lands 5,301 acres Privately owned lands 16,144 acres

Total 25,059 acres

Of the 25,059 acres required for the project, about 12,500 acres are required for gross pool reservoir storage; about 1,800 acres of this land is required for gross pool storage at the existing Melones Reservoir so only up to 10,700 acres of new land will be inundated. Also about 2,300 acres will be available for general public access and resource protection, about 2,900 acres have been designated for intensive use and development recreation areas, and about 2,520 for wildlife mitigation. The wildlife mitigation area, as recommended by the Bureau of Sport Fisheries and Wildlife and the California Department of Fish and Game, includes Peoria Mountain and other undeveloped lands around the south end of the reservoir. An additional 2,293 or so acres of project lands in the Bostick Mountain area north of the dam required for construction of the dam and spillway will be available to wildlife and may be managed as a wildlife mitigation area. The remaining project land around the perimeter of the lake will also be used by wildlife.

A study was initiated in 1970 to determine the need for possible acquisition of lands containing riparian vegetation downstream from the reservoir for fish and wildlife mitigation and enhancement, public access, recreation, and related purposes. This study is being made in response to the legislative requirement to maintain the floodway below Goodwin Dam and will include the recommendations of the Bureau of Sport Fisheries and Wildlife (3) (7) and the California Department of Fish and Game (8) and is currently in progress. Further information on this study is discussed in paragraph 9. In addition, studies are being made regard­ ing possible acquisition of additional lands around the reservoir for protection of environmental values associated with the project and will be reported in the master plan.

6 . Relocations. - About 2.5 miles of existing State Highway 49 at Melones will be relocated, as shown on chart 2, and a new 2,200 foot long bridge will be constructed. About 2 miles of existing county road at Parrott's Ferry will be relocated, as shown on chart 2, and a new bridge constructed. Existing historical monuments at Melones and Parrott's Ferry will be relocated to nearby points along the high­ ways, above gross pool. Existing high-voltage powerlines and telephone lines in the reservoir area will be relocated.

■7. Recreation. - Recreation facilities will initially be provided in three recreation areas. Recreation use is expected to be about 320,000 recreation days annually by the third year after project completion (9). At this use level, about 6,800 persons are expected to visit the project on the average Sumner weekend day. As provided in the authorization for the project (4), the Bureau of Reclamation will be responsible for operation and maintenance of the completed project, including recreation, and will provide for future recreation development subsequent to project completion. Recreation facilities to be developed initially by the Corps of Engineers will be at areas designated as Tut tie town and Mark Twain in Tuolunxie County and Melones in Calaveras County and will include camping and picnic areas with water supply and flush-type restrooms, boat-launching rasps and parking areas, access and circulation roads, and a headquarters and maintenance area. Development of the Glory Hole Recreation Area in Calaveras County is being considered as a possible fourth public use area for Inclusion in the initial construction program. Minor initial facilities are also being considered at Parrott's Ferry and at Camp Mine. Facilities to be provided by concessionaires may include marinas, restaurants, stores, trailer parking areas, lodging accommodations, and equestrian centers. Recreation facilities to be developed in the future are planned to expand the initially developed areas and to develop additional areas. The master plan for public use and conservation and development of the natural resources of the project area is currently 'being developed. Access to die initial recreation areas will be provided— by a paved access road to the Tuttletcwn area from State Highway 49, and utilization of portions of existing State Highway 49 for the Melones and Mark Twain areas. The existing state highway at the latter two areas will be bypassed by the relocated State Highway 49. Construction of a paved access road from State Highway 49 would also be needed to the Glory Hole area. A public observation area has been constructed at the dam and Includes parking, restrooms, landscaping, and a shade shelter. An upstream public overlook and visitor center Is being con­ sidered on a high vista point near the relocated bridge on Highway 49. The overlook-visitor center would Include parking and a visitor center structure, conprising a viewing shelter and displays of project, histori­ cal, archeological, and environmental features.

8. Lake area clearing. - The New Melones Lake Area Clearing Design Memorandum Is presently being prepared. Extensive coordination with various agencies, including those representing fish and wildlife, water quality and public health Interests, will be accomplished in formulating the final design memorandum presently scheduled for completion about February m i . ' “ ~

The design memorandum will give full consideration to environmental protection. Extensive field Investigations have been conducted in the reservoir area with particular emphasis on identifying species of trees that can survive prolonged inundation in order to retain a pleasing appearance in the transition zone in the vicinity of the gross pool level of the new lake. Considerable quantities of brush will also be retained in areas of the reservoir where it would not be a safety hazard for swimming and boating. In specified areas of the reservoir, . significant quantities of vegetation will be retained to provide habitat for fish and wildlife. Lake area clearing as presently envisioned will involve removal of vegetation from elevation 905 to a maximum of about 20 feet below the gross pool elevation of 1,088 feet. Studies will determine the feasibility of retaining certain species of vegeta­ tion within the normal clearing zone in order to create a transitional undulating clearing line. Trees that cannot resist the anticipated periods of inundation will be removed between elevation 1,068 and 905 (except in designated fish management areas). Vegetation below eleva­ tion 905 will not be removed, except for topping of trees, since vegeta­ tion below this elevation will almost always be submerged.

9. Lcwer Stanislaus River. - The lower Stanislaus River, from Goodwin Dam to the mouth of the Stanislaus River will be maintained by the Secretary of the Army to a capacity of at least 8,000 cubic feet per second (c.f.s.) after completion of the dam, provided non-Federal local interests agree to maintain private levees and to pre^bnt encroachment on the existing channel and floodway between the levees (4). The required channel capacity would be maintained without extensive channelization or clearing beyond existing conditions. At objective flocdflow releases of 8,000 c.f.s., some lands adjacent to the river would be inundated under existing conditions. The floodway and lower river contain important riparian vegetation, fish and wildlife habitat, recreation opportunities and some developed agricultural land. Four objectives have been established by the Corps of Engineers for the lower river: a. Provision of a channel capacity of at least 8,000 cubic feet per second and a plan by which the channel can be maintained to that capacity.

b. Preservation of existing fish and wildlife habitat.

c. Preservation of salmon and steelhead spawning gravels.

d. Provision of public access to the river.

In response to reconmendations from the State and Federal fish and wildlife agencies and to accomplish the established objectives, the following alternative concepts have been developed for Stanislaus River downstream from Goodwin Dam to the San Joaquin River. These concepts were presented at a public meeting held in Modesto on 2 March 1972.

Estimated Concept Description Estimated Cost No. Acres ($ millions)

la Acquisition in fee of significant riparian resources. 8,000 13.0 lb Acquisition by easement of all signi­ ficant riparian resources, except that fish gravels and 11 public access areas would be acquired in fee. 8,000 11.5 2a Acquisition in fee of about one-half of the significant riparian resources. 3,900 6.5 2b Acquisition by easement of about one- half of the significant riparian resources, except that fish gravels and 7 public access areas would be acquired in fee. 3,900 5.5 3a Acquisition in fee of 2 significant riparian resources areas, fish gravels and 5 public access areas 2,130 3.0 3b Acquisition by easement of 2 significant riparian resource areas, plus fee acquisition of fish gravels and 5 public access areas. 2,130 2.5 4a Acquisition by easement of the existing 8,000 cubic feet per second floodway, plus fee acquisition of fish gravels. No acquisition of public access areas. 6,000 8.0 4b Zoning of the existing 8,000 cubic feet per second floodway. No acquisition of fish gravels or public access areas. 6,000 0 These alternatives are under consideration and one of them, or a varia­ tion, will be lnplemented by the Corps of Engineers pursuant to Congres­ sional authority (4) prior to completion of project construction.

10. Basis of determining costs and benefits. - The total cost of construc­ tion of...the project is presently estimated at $181,000,000, based on 1971 price levels. This cost Includes about $23 million dollars for engineer­ ing and design, supervision and administration of construction, and real estate costs for acquisition of required project lands in addition to contract construction costs. Presently the cost estimate does not Include possible cost of acquiring lands along the lower Stanislaus River, as described in paragraph 9, since the plan for that part of the river has not yet been determined. Total funds expended to date have been about $28,000,000. On an annual cost basis, assuming an economic life of ’ 100 years and using an interest rate of 3-1/8 percent, annual costs are estimated at $7,841,000. This amount includes normal operation and main­ tenance cost of the project as well as cost of replacement of project features having an estimated physical life of less than 100 years.

Project benefits have been computed pursuant to guidelines and pro­ cedures of the Water Resources Council, Senate Document No. 97, 87th Congress, and the Chief of Engineers.

Flood control benefits are estimated at $1,940,000 per year. The bulk of the flood control benefits were computed as the difference in expected average annual damages with and without the project, over the 100-year economic life of the project. These benefits consist of: (a) physical damages prevented, largely agricultural in nature; (b) flood fighting and emergency repair costs prevented; and (c) business losses prevented. In addition, nominal amounts of improved land use benefits, and benefits due to prevention of bank erosion were evaluated. Benefits are based on the state of development expected to prevail in the flood plain during the 100-year project period.

Irrigation benefits are estimated at $3,610,000 per year. These benefits were estimated by the Bureau of Reclamation on the basis of a new water supply in the area of the San Joaquin Valley. Primary benefits were evaluated on the basis of increased net crop income resulting from use of the project water supply. The net farm income is based on crops grown and yield of those crops under present farming practices. It is expected that crops grown in the future will be essen­ tially the same as those grown today. The benefits include increased Income resulting from reduced ground water pumping costs and Increased ground water supply, as well as the increased income from surface applica­ tion of the new water supply. The total benefits at the farm have been adjusted to reflect distribution and conveyance costs and costs of pumping power. Benefits have been computed on the basis of reaching full development 15 years after the project begins operation. If the new irrigation water Is used in service areas other than the southern San Joaquin Valley, the estimate of benefits Is not expected to materially change.

Power benefits accruing to the Hew Melones Lake project were based on studies of an integrated operation of CVP by the Bureau of Reclamation, Including the 300,000 kilowatt pcwerplant at New Melones. The new project is estimated to provide an average of 430,000,000 kilowatt-hours of energy to the CVP system. Power benefits were computed on the basis of cost of a non-Federally financed steam plant located near the load center, using values of capacity and energy furnished by the Federal Power Commission.

General recreation benefits averaging $910,000 per year were computed on the basis of estimated increase in recreation days of use in the area made possible by the construction and operation of the project. General recreation use is expected to be about 320,000 recreation days initially, Increasing ultimately to about 4,000,000 recreation days after conpletlon • of the project. Recreation use estimates for New Melones Lake were derived by employing a distance-* « » a H t n « M n g forhrHqna. With this technique per capita use rates derived from observations at an existing reservoir are applied to the populations of the zonal areas comprising the proposed project's recreation market demand area to estimate expected use. Reductions in the project's market area are made when judged neces­ sary to compensate for recreation competition from existing reservoirs. When estimating use over time, the technique can accommodate changes in the zonal populations and changes in the zonal per capita rate. The zonal populations are initially derived from current census data and then projected over the life of the project using population growth information. Changes in the per capita use rates are projected in proportion to projected changes in the State per capita use rates for outdoor recreation as derived from historic data. For project evaluation one estimate of annual benefits is made for each decade over the 100-year repayment period of the project. Ihese estimates aze then converted to average annual equivalent benefits using the applicable interest rate in consonance with sound economic and project formulation practices. This level of use is expected to continue for the remainder of the project life. A unit value of $1.00 per recrea­ tion day has been used to compute the general recreation benefits.

Fish and wildlife benefits are estimated to average $640,000 per year. The fish and wildlife benefits (excluding commercial fishing benefits) were computed on the basis of the expected increase in fishing use both at the reservoir and downstream of the reservoir which will be made possible by construction and operation of New Melones Lake. Increase in equivalent fishing use at the reservoir over preproject use was esti­ mated to average 380,000 fisherman-days per year, and the increase in equivalent fishing use downstream from the reservoir over preproject use was estimated at 8,000 fisherman-days of trout fishing and 76,000 fisherman-days of sport fishing for steelhead and salmon per year. Reservoir and downstream trout fishing were evaluated at $1.00 per fisherman-day and the salmon and steelhead fishing were evaluated at $2.50 per fisherman-day. In addition to trout and sport fishing, bene­ fits will accrue to commercial fishing for salmon due to improved down­ stream conditions. The U.S. Fish and Wildlife Service estimates that under ultimate project conditions, the downstream fishery will produce an increased annual Conner da l catch of about 18,000 fish creditable to the New Melones Reservoir. These fish will be available within the first few years after completion of the project. The benefit accruing because - of these increases in the commercial fish catch was estimated at $3.35 per ^fish, or a total of $60,000 per year.

Water quality control benefits are estimated to average about $180,000 per yearl Benefits accruing to water quality control xor irrigation uses were derived by the Pt&lic Health Service on the basis of controlling the water quality in the lower San Joaquin River to 500 ppm total dissolved solids. Studies indicated that this control will require an annual equiva­ lent release from the reservoir of 7,900 acre-feet of water, on the average. Evaluated at $20.00 per acre-foot, the estimated cost of water from an alternative source, the average annual equivalent benefits to irrigation creditable to water quality control would be $158,000. Studies by the Public Health Service for water quality control for the downstream fishery were based on maintaining the dissolved oxygen (D.O.) concentration in Stanislaus River to at least 5 ppm, which would prevent future damage to the downstream fishery. This will require A,100 acre-feet of water from New Melones Reservoir by the year 202 5 and 25,100 acre-feet by 2075. A Evaluated at $1.00 per fisherman-day for that fishing use made possible by water quality control operation, the annual equivalent benefits will be about $22,000.

Area redevelopment benefits are estimated to average $635,000 per year. — Tliesg-beueflLs are based On that'part of construction, operation and maintenance costs which represent wages to workers who, in the absence of the project, would be unemployed. Such benefits are claimed only for project areas having substantial chronic and persistent unemployment and underemployment so designated by the U.S. Department of Commerce. Tuolumne County is currently so designated.

11. Summary of costs and benefits. - The total cost of construction of the project is presently estimated at $181,000,000. an"irl rnfitff are estimated at $7,841,000. Average annual benefits for the various project purposes are listed below.

TABLE 3 - AVERAGE ANNUAL BENEFITS

Flood control $ 1,940,000 Irrigatio n 3,610,000 Power generation 5,578,000 General xecreation 910,000 Fish and w ild life 640,000 Water quality control 180,000 Area redevelopment 635.000

Total Annual Benefits $13,493,000 The benefit-cost ratio of the project is 1.7 to 1. SECTION II - ENVIRONMENTAL SETTING WITHOUT THE PROJECT

12. General description of Stanislaus River Basin. - The Stanislaus River above New Melones damsite drains an area of about 900 square miles, ranging in elevation from about 700 feet to over 10,000 feet at the crest. Most of the watershed is on lands within the Stanislaus National Forest, administered by the U.S. Forest Service. The three major tributaries (North, Middle, and South Forks) flow in steep, rocky canyons to the New Melones Lake area where they join. Two relatively large reservoirs, Beardsley and Donnells, are on the Middle Fork. In the higher areas, meadows have been dammed to form small lakes at Lyons and Pinecrest (South Fork), Relief (Middle Fork), and Utica, Union, and Spicer Meadows Reservoirs (North Fork).

Around the project area the terrain graduates from a predominantly steep-sided canyon to narrow, flat-topped ridges generally covered with grass, chaparral, and scattered trees. The existing Melones Reservoir was constructed in 1926 by the Oakdale and South San Joaquin Irrigation Districts and forms a lake with relatively steep sides in this area. Downstream from the New Melones damsite are two additional , Tulloch and Goodwin. Below Goodwin Dam the river flows through less steep grass­ lands and finally meanders through the flat San Joaquin Valley to its junction with the San Joaquin River.

13. Climate. - The Stanislaus River Basin has a temperate, semiarid climate characterized by hot, dry summers and cool, wet winters. Temperatures at the damsite have ranged from a summer high of 113° Fahrenheit to a winter low of 14* Fahrenheit. The following tabulation shows the estimated values for the average maximum, minimum, and mean monthly temperatures at the project area, based on historical temperature data observed at Sonora, California.

TABLE 4 - AIR TEMPERATURE AT SONORA. CALIFORNIA

Temp *F Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Avg max 59 63 68 75 82 91 98 96 88 78 68 61 Avg min 40 43 45 49 53 60 66 64 60 52 45 41 Mean 50 53 57 62 68 76 83 81 74 65 57 51

Temperatures may drop below freezing for a few hours of several consecutive days during the winter, but no extended periods of subfreezing temperatures occur at the damsite. Normal annual precipitation varies from 65 inches in the upper part of the basin to 27 inches at the damsite and averages about 46.8 inches over the drainage area above the damsite. About 90 percent of the annual precipitation occurs during the period from November through April and results mainly from storms originating over the Pacific Ocean. Precipitation may occur as snow or rain at the higher elevations, and generally occurs as rain in the lower elevations of the basin. Above 4,000 feet snow usually accumulates during the winter months and melts during the spring.

14. Streamflow. - Flows below the New Melones damsite vary greatly according to precipitation in the basin. There is also considerable variation due to existing irrigation diversions and return flows. The average monthly streamflows of record are shown below for three locations along the Stanislaus River. Goodwin Dam is the diversion point for Oakdale and South San Joaquin Irrigation Districts and periodically there are virtually no flows below Goodwin Dam due to such diversions. Irrigation return flows are of considerable quantity and maintain perennial flow downstream of Ripon.

An indication of the amount of variation in streamflow between different years is given by the following tabulations (table 5b and 5c) which are based on the five highest and the five lowest water months during the period of record (1921 to 1946). TABLE 5 - AVERAGE RIVER FLOWS (Flows at three locations on the Stanislaus River)

Below Month New Malones dcaslte Knights Ferry Ripon

(values are In cubic feet per second)

A - AVERAGE MONTHLY FLOWS

Jan 742 370 485 Feb 1,446 1,199 1,389 Mar 1,791 1,654 1,804 Apr 2,565 1,582 1,757 May 3,846 2,409 2,539 Jun 2,608 920 1,145 Jul 1,243 30 245 Aug 894 0 155 Sep 566 G 175 Oct 430 0 160 Nov 329 0 110 Dec 510 87 177

B - AVERAGE MONTHLY FLOWS - FIVELOWEST MONTHS

Jan 315 0 115 Feb 330 0 190 Mar 560 89 239 Apr 979 39 214 May 1,253 0 130 Jun 1,105 0 225 Jul 719 0 215 Aug 551 0 155 Sep 378 0 175 Oct 363 0 160 Nov 300 0 110 Dec 301 0 90

C - AVERAGE MONTHLY FLOWS - FIVE HIGHEST MONTHS

Jan 1,790 1,599 1,714 Feb 3,270 3,055 3,245 Mar 3,715 3,605 3,755 Apr 4,290 3,300 3,475 May 6,445 4,890 5,020 Jun 4,908 2,994 3,219 Jul 1,511 136 351 Aug 1,038* 0 155 Sep 658 0 175 Oct 451 0 160 Nov 404 0 110 Dec 1,179 434 524 15. Flood potential. - During winter or spring, warm-type storms may move over the basin at which time precipitation occurs as rain instead of snow at the higher elevations. The most serious rain flood potential Is produced when these warm rains fall on a saturated light snowpack and the snowmelt combines with the rain runoff. The highest peak flow during the period of record (Inflow to existing Melones Reservoir) was 102,000 cubic feet per second. This occurred on 22 December 1955 with the regu­ lated peak flow at Ripon at this time being 62,500 cubic feet per second.

High sustained streamflow gradually occurs during May and June when rising daily temperatures cause the snowpack to melt. The snowmelt flood potential varies according to accumulated water content of the snowpack and the temperature. The standard project rain flood is estimated to have a peak flow of 148,000 cubic feet per second, a 5-day volume of 377,000 acre-feet, and a standard project flood series, would have a 20-day volume of 655,000 acre-feet. The standard project snowmelt flood is estimated to have a maximum inflow of 16,000 cubic feet per second to the reservoir. Without the project, up to 35,000 acres of highly developed agricultural land along the Stanislaus River and suburban areas of Oakdale, Riverbank, and Ripon will continue to be subject to periodic flooding. In addition, Stanislaus River floodflows will continue to aggravate flood­ ing along the lower San Joaquin River and the Sacramento-San Joaquin Delta.

16. Water quality. - Water quality studies by the U. S. Public Health Service (10) have been made for the areas adjacent to the Stanislaus River lying below the damslte and the areas of beneficial uses of San Joaquin River waters below the mouth of the Stanislaus River. Oakdale, Riverbank, Salida, Escalon, and Ripon, with a combined 1970 population of about 17,044, are located along the Stanislaus River. These communi­ ties serve as a local processing and supply center for the highly developed irrigated agricultural lands adjacent to the river. Wastes from the urbanized areas receive primary treatment and discharge to holding ponds. Effluents from the ponds are discharged to the Stanislaus River when pond capacities are exceeded for short periods during the canning season. This has caused the dissolved oxygen (D.O.) concentrations between River­ bank and Ripon to drop below 1 milligram per liter (mg/1) on many occasions with the low D.O. condition extending a considerable distance downstream. The D.O. concentration in the Stanislaus River is over 6 mg/1 most of the time (10). When the concentration of dissolved oxygen falls below the 85 percent saturation median during the critical life cycles of fish, it can affect the fishery for many years. This is particularly true for cold water species such as salmon and trout. (See Department of Interior Comment Number 11 in appendix A.) Pertinent information from the U.S. Public Health Service water quality studies is presented below. "The quality of Stanislaus River water, above the waste discharge points, and the quality of the ground J water is suitable for all beneficial uses in the Stanislaus River Basin. Quality of the Stanislaus River at Tulloch Reservoir is very high. The chemical quality meets U. S. Public Health Service Drinking Water Standards in all respects and, with adequate treatment, is capable of meeting the physical and bacteriological standards at all times." The following table Illustrates the surface and ground water quality of water in the Stanislaus River Basin.

TABLE 6 - SURFACE AND GROUND WATER QUALITY IN THE STANISLAUS RIVER BASIN (10)

Municipal Stanislaus River Near Ground Water at Tulloch Reservoir(a) Mouth (a) Supplies (b) ssIX mg/1 TDS 25-175(c) 32-226 86-288 Total Hardness 0-19 21-197 49-151 Alkalinity - - 46-152 Chloride 0-7 0-24 5-29 Sulfate 0-7 0-11 1-22 Nitrate-Nitrogen 0-0.3 0-0.6 1-6 Fluoride 0-0.2 0-0.3 0.1-0.2 Calcium 4.9-25 5.5-31 11-33 Magnesium 0.5-9.5 1.2-14 5-17 Sodium 1.3-15 1.5-22 17-25 Aluminum .02-.12(d) .02-.11(d) -

Iron (Total) - 1.0-0.76(d) 0 . 1 Copper 0 .01(d) 0 .01(d) Zinc 0 .01(d) 0 .01-0.02(d) - Lead - 0 .01(d) - Manganese - 0 .01(d) - Chromium - 0 .01(d) - Arsenic 0 .01(d) -

(a) Period of record, July 1956 to December 1961 at Tulloch and April 1951 to Decenber 1961 near mouth. Source is California Department of Water Resources Bulletin No. 65-61. (b) Supplies of Oakdale, Escalon, Riverbank, Ripon, and Salida. Source is California Domestic Water Supplies, State of California, Depart­ ment of Public Health, 1962. (c) Median annual flow weighted concentration from 1958-1963 was 41 mg/1. (d) Data from reference (12); near mouth is station at Koetitz Ranch. « There Is no Indication of significant quantities of heavy metals existing in the drainage basin upstream of Melones Dam. A source of copper in Tulloch Reservoir (table 6) is Copperopolls Camp in southern Calaveras County which is drained by tributaries of Black Creek that form the large, northern arm of Tulloch Reservoir. Ccpperopolis Camp was a major producer of copper until 1945. In 1958, cement copper was produced by precipitating copper from mine water (17). During the first heavy rainstorms of the year and, during episodes of shaft dewatering, as occurred in 1956 and 1958, relatively high concentrations of copper could be expected in Black Creek and subsequently in Tulloch Reservoir.

Additional information from the report of the Public Health Service (10) is quoted as follows:

"The quality O f the Water in thfj -TnaqiHn IHiraT-, halm r thn-mru.l-h of the StanlsTguS River, is generally pnnr except during floodflows. During summer months, the concentration of total dissolved solids normally ranges upward from 500 mg/1 and has exceeded 1,200 mg/1.

Periodic pollution of the lower Stanislaus River waters and perennial pollution of the lower San Joaquin River waters is adversely affecting the use of these waters for municipal, industrial, agriculture, fishing, and recreation.” (10)

Even the beneficial use of navigation in the lower San Joaquin River and the Delta is affected by the present poor water quality conditions. The Environmental Protection Agency and the Central Valley Regional Water Quality Control Board have advised that further deepening of the Stockton Ship Channel as a part of the authorized navigation project, San Francisco Bay to Stockton (13)(14), should not be undertaken by the Corps under present water quality conditions since this could lead to degradation of water quality in this critical area (15)(16).

The total dissolved solids concentration in the Stanislaus and San Joaquin River basins is a function of flow. During low flows in the Stanislaus River Basin, the total dissolved solids concentrations have Increased from the median annual flow weighted concentration of 41 mg/1 to a maximum daily concentration of 226 mg/1 during 1964, a drier than normal year (10). The diluting effect of the Stanislaus River outflow is important in controlling the total dissolved solids concentrations in the San Joaquin River at Vemalis. Even though the quality of the Stan­ islaus River is acceptable for irrigation use, the diluting effect is reduced because of the increased total dissolved solids concentrations and further reduction in flows due to consumptive use during low flow years. The* summertime flows of the San Joaquin River at Vemalis are comprised mainly of Irrigation return flows. The State of California has responsibility for planning, management, and enforcement of water quality programs in the two river basins. The Interim Water Quality Management Plan (18) principally addresses itself to the municipal and industrial wastes. The interim plan is the initial step toward a more comprehensive "Fully Developed Water Quality Control Plan," to be completed by 1 July 1973. Prior to Implementation, a water quality control plan must be approved by the Environmental Protection Agency. The unresolved water quality control problems will be discussed in the Regional Water Quality Control Plans (Basin Plans) during the period 1 July 1971 to 1 July 1973. The majority of the total waste load in waters of the lower San Joaquin River Basin is contributed by the agricultural industry, which is the principal land use; 90 per­ cent of the water used in this area is for agricultural use (18).

17. Anadromous fish. - There are about 59 miles of king salmon habitat in the Stanislaus River drainage (19). Of this about 25 miles contain suitable spawning areas.' Goodwin Dam is the upstream limit of migration. Department of Fish and Game's spawning stock estimates (20) are as follows:

TABLE 7 - ANNUAL ESTIMATES OF KING SALMON MIGRATING UP THE STANISLAUS RIVER

Year No. of Fish Year No. of Fish

1953 35,000 1962 300 1954 22,000 1963 200 1955 7,000 1964 4,000 1956 5,000 1965 2,200 1957 4,000 1966 2,900 1958 6,000 1967 12,000 1959 4,000 1968 6,000 1960 8,000 1969 12,000 1961 2,000 1970 9,000

The wide range in number of salmon migrating upstream, from 200 to 35,000 per year, is attributed to varying conditions. The single most important factor is probably flows in the river during the time that both spawning salmon and young salmon are in the river. An example of how low flows in the Stanislaus River adversely affect salmon has been documented by the California Department of Fish and Game (21). At times the irrigation demands have reduced the flows so early in the year that millions of young salmon have failed to make their downstream migration and have failed Co survive the high summer temperatures in the river. At times, barriers to salmon migration are placed in the Stanislaus River in the form of temporary earth dans erected to facilitate irrigation pumping (19). In the past, water diversion works have removed large numbers of fish, particularly immature fish migrating downstream. Presently State statutes require that all diversions be screened. During many months, while both spawning and young salmon are in the river, water temperature is not suitable (according to Bureau of Sport Fisheries and Wildlife temperature criteria as discussed in paragraph 31) under present condi­ tions. This can be seen in table 15, paragraph 31, showing the number of times that a month is not within the temperature range specified by the Bureau of Sport Fisheries and Wildlife as acceptable for fish. Spawning gravel available to king salmon has steadily declined since the construction of existing Melones Dam. Existing Tulloch, Melones and Goodwin Dams block natural recruitment of gravel and the remaining gravels are being mined for building material at an Increasing rate.

Steelhead trout spawn generally in the same areas as the salmon but cannot utilize the river under existing conditions due to unfavorable summer flow and temperature conditions. Striped bass and American shad spawn in the downstream reaches of the Stanislaus River below Orange Blossom Bridge. Sturgeon are also present in the lower reaches. At present there is no estimate of the numbers of striped bass, American shad, or sturgeon that ascend the Stanislaus River.

An important factor affecting anadromous fish ascending the San Joaquin River on their way to the Stanislaus River is the pumping plant complex located near Tracy in the southwest corner of the Sacramento- San Joaquin Delta. These pumps lift water from the Delta into the Delta-Mendota and the California Aqueduct for conveyance to the south. Such large quantities of water are withdrawn from the Delta by these pumps that the normal downstream movement of water has been reversed at times in some main channels (22)(23). Another important factor affecting anadromous fish ascending to the San Joaquin River occurs at Stockton. Reduced flows past Stockton, along with pollution discharges there and agricultural return flows from upstream result in a dissolved oxygen deficiency "block" which adversely affects the upstream migration of salmon bound for the Stanislaus River (23). Accord­ ing to the Central Valley Water Quality Control Board, "Our water quality control policy for the Delta establishes a lower limit for oxygen at 5.0 mg/1. For many years we have been endeavoring to attain this value by stringently regulating waste discharges in the area (San Joaquin River near Stockton, California). However, despite our efforts we have not been able to consistently attain the oxygen levels needed to protect and enhance the migratory salmonold and resident fish resource." (24) In most years the block clears up in time for the salmon to reach the spawn­ ing beds, though in 1961 it did not clear up, significantly affecting the size of the run.

Less than 10 percent of the Stanislaus River shoreline is accessible to the general public since almost all adjacent lands are in private owner­ ship.

18. Resident fisheries. - The 16-mile reach of the Stanislaus River upstream from Melones Reservoir to the Stanislaus Powerhouse at Camp Nine, supports a rainbow trout fishery that is supplemented by stocking with catchable-sized rainbow trout by the California Department of Fish and Game. It is estimated that 20,000 angler days occur annually in this reach (8). A warm water fishery exists in the reach downstream from Goodwin Dam and includes smallmouth bass, largemouth bass, white catfish, black crappies, bluegills, and green sunfish. Carp, squawfish, hardheads, and other non-game fish are numerous. It is estimated that 45,000 angler days are expended annually in this reach below Goodwin Dam with more than 80 percent of the catch being composed of white catfish (8). The fishery in existing Melones and Tulloch Lakes is similar in species composition to the resident downstream fishery. It is esti­ mated that 33,000 and 30,000 angler days, respectively (3), occur annually in these lakes.

19. Vegetation. - Vegetative information has been collected during the course of design memorandum studies by a consultant (25) and the Corps of Engineers and is summarized below. The New Melones Lake project area ranges in elevation from about 700 to 2000 feet. The vegetation at these elevations is typical of that found in the foothills of the west slope of the Sierra Nevadas.

The reservoir area, at about 1,000 feet elevation, has vegetation which is characteristic of the Upper Sonoran life zone (26)— scattered blue oaks, digger pines, and an understory of chaparral shrubs, such as toyon and chamise, and grasses and forbs. In places buckbrush has replaced pine trees, probably as a result of fires.

The vegetation of the upstream canyon area of the project is noticeably different in composition from the reservoir area. It trends toward the transition life zone of the Sierra Nevadas, distinguished by black oaks and various conifers— yellow pine, douglas fir, and incense cedar. The grassy understory which is evident in the reservoir area has largely been replaced at this elevation with thick chaparral shrubs, including manzanita. Riparian vegetation is noticeably absent at the reservoir site, but alders and willows are common along the river in the canyon area.

Between Goodwin Dam and Knights Ferry, a distance of about four miles, the river is restricted in a narrow rocky-bottcmed canyon and the border of riparian vegetation is narrow and thin. Fremont cottonwood, California buckeye, willows and forbs are characteristic riparian species and the steep canyon sides support a number of upland species including digger pine, several species of oaks (interior live oak, blue oak, canyon live oak and California black oak), as well as white alder, redbud, Pacific madrone and manzanita.

Downstream from Knights Ferry, the terrain flattens out and the Stanislaus flows for another 50 miles to join the San Joaquin River in the midst of the valley. Here the native vegetation, other than the riparian association, is characteristic of the Lower Sonoran (valley) life zone-scattered valley oaks and perennial grasses. Most of this native vegetation has been supplanted by intensively cultivated pasture, orchard, and cropland. Since natural vegetative values away from the river have been largely replaced by man's activities, the abundant riparian vegetation within the river's floodway provides an important scenic aspect for the region in addition to the intrinsic values of the numbers and kinds of vegetation and its uses.

Riparian vegetation is continuous along the river but varies greatly in width. The most extensive sections of riparian vegetation occur down­ stream from Riverbank where the river meanders and forms a larger flood plain. The characteristic trees are Fremont cottonwood, valley oak, sycamore and ash. Tall trees (50 to 75 feet high) with broad leaves form a shady canopy over an often dense understory of shrubs and vines. The vegetation extends from the waters edge to cutbanks that delineate the river's meandering at high water stages or a limit set by agricultural operations. When trees occur in groves, an understory of shrubs and vines typically grow in association. Rose, blackberry, blue elderberry and grape are dominant plants in the understory. Each of these species is a prolific producer of fruit and the roses and blackberry form dense cover. Willow thickets line the river, especially on sandbars and along the outer bank of river bends, where flood waters prevent the growth of trees. Dense weedy cover occurs in some areas. California ringwort is a typical plant of the weed communities. The riparian vegetation has a high aesthetic value and contains the only significant stands of trees in the general vicinity. In summer its greenery and shade is appealing and in fall, the colored leaves enhance the scenery. The dense cover and abundant food produced by the riparian vegetation make it a high grade wildlife habitat. The various forms of vegetation including the overstory of the tree canopy and the thicket understory coupled with the adjacent water attracts a large variety of wildlife species. The concentration of wildlife coupled with a pleasing habitat for people makes the riparian area an ideal place for wildlife observation.

A number of uncommon plants are known to be found in Calaveras or Tuolumne counties (27). A list of those which could occur in the reser­ voir area is as follows:

Brodlaea pallida Hoov. Balsamorhiza macrolepis Sharp. Lupinus spectabills Hoov. Erythronlum tuolumnese Applegate.

None of these species is, however, known to have been found in the area that will be affected by the project.

20. Wildlife. - Wildlife information has also been collected for design memorandum studies by a consultant (25) and by the Corps of Engineers and is summarized below. More detailed listings are Included in the consultant's report. Species found in the reservoir area are typical of those associated with the Upper Sonoran life zone. The most conspicuous mammal, because of its size, is the California mule deer. The area to be inundated supports a resident herd of about 500 deer which is supplemented in the winter by migratory individuals which move to lower elevations to feed (8). Although more commonly found at higher elevations, mountain lions occasionally move into the reservoir area to prey on deer.

Upland game such as California quail, brush and cottontail rabbits, and gray squirrels are common in the area as are mourning doves which nest in the area and are commonly seen between March and September. About 1,600 California quail inhabit the reservoir area (8). Band-tailed pigeons are occasionally seen migrating through the area in the winter.

The mild climate, cover pattern, and abundance of food make the reservoir area attractive to wintering non-game birds and their predators. The variety of bird species that can be observed makes it a good place for recreational bird watching. The furbearers found here include raccoons, coyotes, striped and spotted skunks, gray and red foxes, and muskrats. Most of these, as well as many of the local small terrestrial mammals, reptiles, and amphibians, have secretive or nocturnal habits and go largely unnoticed by humans.

The existing Melones Reservoir is an extrinsic habitat and has attracted a few species that were not originally found in the area. These are water birds and include ruddy, ring-necked and mallard ducks, grebes and coots. Any of the waterfowl that frequent the San Joaquin Valley may on. occasion land and rest on the reservoir. It is a poor quality habitat for waterfowl and cannot support them in significant numbers.

Bald eagles, an endangered apggles. have been sighted in the reser­ voir-area, but are not known to nest there.No other rare or endangered 'species Are known to exist in the area.

With the change in vegetation in the upstream areas toward that of the transition life zone comes a change in wildlife composition toward those species which rely on forest vegetation and are more resistant to cold weather. Such visible indicator species as mountain quail, porcu­ pines, and the raucous Steller's jay are seen here. Black bears probably also frequent the area. Many species such as deer are found in both the reservoir and upstream areas.

There are several small birds and mammals which rely, to one degree or another, on upstream riparian habitat. One of these is the northern water shrew which is totally dependent on this habitat type. Another is the water ouzel or dipper, an interesting little bird which feeds on aquatic invertebrates found on the bottom of swift streams. Ouzels feed and nest in the upper reaches of the project area and are seldom seen in the valley. Insectivorous birds such as the yellow warbler, although not tied to riparian habitat, are attracted to it during the summer months.

In the canyon,40 air miles and two drainages away from the New Melones Lake project area, a rare amphibian, the limestone salamander (Hydromantes brunus) is found. On the possibility that this salamander might be found in the New Melones Lake area a field study was conducted. No salamanders were found. As a verification, the same study team searched the Merced River area and found nine limestone salamanders in a very short time (28). As the terrain along the lower Stanislaus River flattens out and becomes part of the San Joaquin Valley, the thick riparian growth along the river and the vast expanse of agricultural land in the valley provide habitat for many of California's small mamnals and birds.

The San Joaquin' Valley is a great wintering area for waterfowl and 5 on occasion, any species of puddle duck may use the river as a resting area. The wood duck is one that is most fond of the riparian habitat and is dependent upon it for its existence, nesting primarily in trees near water. The water within the San Joaquin Valley, in combination with the vegetation, attracts wading birds and some shore birds. The riparian habitat is very attractive to wintering passerine birds.

Riparian habitat acts as a home base for many wildlife species, enabling then to use surrounding agricultural area that would be too open in itself. This foraging on agricultural areas is at times in conflict with the farmer's objectives, but in the fall and winter, fruits and nuts left unharvested provide food for wildlife without any costs to man. One reptile, the giant garter snake (Thamnophls couch glgas). desig­ nated rare, is listed as a resident of the valley floor in this area.

21. History and archeology. - The Mother Lode foothill region is rich in pioneer history. This was the setting for the famous "" of 1849 and 1850. Many old buildings, ruins, abandoned mines, ferry sites, and local place names remain from this era. These are described in detail in "Mines and Mineral Resources of Calaveras County, California" (17). Much of a small city, Columbia, only a few miles from the New Melones Lake, is being preserved and restored by the State of California as the Columbia State Park. This is an Important and popular tourist attraction. Mark Twain wrote his "Jumping Frog of Calaveras County" and other works in this area. A cabin once used by Mark Twain is pre­ served on Jackass Hill near the site of New Melones Lake. About 230 ^archeological sites in and around the lake area give evidence Of populations of Mi-wuk and other Indian tribes. Virtually all of these sites are close to streams and rivers. The most prominent feature at most of these sites is the bedrock mortars used by the Indians for grinding acorns and other nuts. To date more than 12 sites have been excavated and some bones, arrowpoints, and broken pots have been recovered (29). There is one known paleontological site in the area. Many of the caves in the vicinity of the project contain skeletons of Indians and gold miners, since caves provided a convenient means of disposing of bodies without the necessity of digging in the hard, rocky ground. Indian petroglyphs are located on the face of a cliff about 100 feet above the river and approximately three quarters of a mile upstream from the Parrott's Ferry Bridge (30). Examination of the "Register of Historic Places, 1969" and subsequent Notices in the Federal Register (31) reveals no National Historic Places that will be adversely affected by the project. The Robinson's Ferry, Parrott's Ferry, and Abbott's Ferry are historic places cited in the State of California's "California Historical Landmarks" (32) and are located in the area to be inundated by the new lake. Robinson's Ferry, located just downstream from the existing Highway 49 Bridge, was operated at peak use from 1850 to 1851. In a six-week period during that time, about $10,000 in ferriage tolls was collected. This was replaced by a masonry arch bridge in about 1910 by Tuolumne and Calaveras counties, which collapsed about 1952, and was replaced by the present concrete State Highway bridge in 1953. Abbott's Ferry, located about one mile upstream from the existing Parrott's Ferry Bridge, was operated from the early 1850's until the 1890's as a crossing for the stage road from Columbia to the Vallecito-Douglas Flat mining area, forking to Murphy’s and Angels Camps. During the flood periods, especially the wet years of the 1860's, the ferry would periodically be washed down river. Remains of the stage stop station with horse corrals are visible on the Tuolumne County side of the river. On the Calaveras County side of the river, about one mile north of the ferry site in Skunk Gulch, ruins of an eating and rest shelter remain. From this point, a road branched southwest to Angels Camp, via the upper natural bridge over Coyote Creek. A cabin from this era remains nearby and is still used. Just before the turn of the century, Parrott's Ferry began operation about one mile downstream from Abbott's Ferry in conjunction with the toll trail from Columbia and between the Duchess and Densmore Mines and other settlements on both sides of the river. About 1905, a new toll road was built to handle autos and a ferry for automobiles was operated. Periodically, as with all Mother Lode ferries, it was swept away during floods. Concrete abutments and cables are still visible. In the 1920's the toll road was purchased by the counties and a bridge was built to replace Parrott's Ferry. This bridge was subsequently washed away in a flood and was replaced about 1940 by the existing concrete Parrott's Ferry Bridge. The foundations of extensive mining operations, especially about a half mile below the present bridge, along with parts of the landing for Parrott's Ferry are still visible. Other sites in the vicinity of the project, listed in "California Historical Landmarks," include:

Tuttietown Mark Twain Cabin Archie Stevenot's Birthplace Carson Hill 22. Geological features and ground water. - The reservoir area is under­ lain by metaraorphic rocks, chiefly greenstone, quartzite, and slaty rocks, ostly mantled with residual clay soil. The rocks are generally impervious except for scattered water filled joint cracks. East and south of the main reservoir area is a flat-topped ridge called Table Mountain, a promi­ nent landmark which consists of a narrow sinuous volcanic flow. The flow filled an ancient river Galley and covers gold-bearing gravels which were extensively mined from tunnels on both sides of the ridge.

Carson Hill, on the northwest side of the river near the existing Highway 49 bridge, is a site of a major gold mining camp which operated from 1850 to 1942. The New Melones project gets its name from the existing Melones Reservoir and in turn from the old settlement of Melones on the south side of Carson Hill, along the river. Melones was named after placer gold nuggets shaped like melon seeds, found in river gravels near the present Highway 49 bridge. The chief remaining visible features of the Carson Hill mines and Melones area are huge open cuts on top of Carson Hill, portals of several tunnels near the remains of Melones, the founda­ tions of a large stamp mill at Melones and a large tailings pile covering about 30 acres one-half mile northeast of Melones.

In the upstream reservoir area are large limestone bodies, in which solution caves and cavities are scattered, containing notable features. These include commercially operated Moaning Cave near Vallecitos, two significant natural bridges in the same area, and over 70 known caves on both sides of the Stanislaus River near and above the mouth of the South Fork. Moaning Cave is a vertical cave containing a large room 150 feet in diameter and at least 100 feet deep where many dripstone formations can be seen. Other chambers go much deeper— to 450 feet. This room is now well-lighted and entered via a 100-foot enclosed steel spiral staircase. Temperature is a constant 59°. It has been com­ mercially operated since 1922. The two natural bridges are remnants of caves and are located about 1 and 1-1/2 miles downstream from Moaning Cave over Coyote Creek. The upper one (elevation 1150) is longer, higher, more beautiful and less vandalized (so far); the lower end of the lower cave (elevation 1083) opens to a popular, gravelly picnic area and pool. The upper bridge was part of a stagecoach route in Gold Rush days between Abbott's Ferry (and Columbia) and the Angels Camp area. A National Speleological Society Task Force has assembled detailed preliminary information concerning caves in this area as an assistance in determining their importance (30)(33)(35). At least 60 of the caves in the upstream reservoir area are named, known and visited. Some of the larger, better known caves, besides Moaning Cave, include Catarach Gulch Cave, Crystal Palace Caverns, Crystal Stanislaus Cave, Grapevine Gulch Caves, Heater Cave, McLean's Cave, McNamee's Cave, Pinnacle Point Cave, Pine Log Cave and Snell's Cave. Many of these caves contain speleothens and chambers con­ nected by passageways. Each cave Is unique In Its own characteristic way, and in-depth treatment is not possible. The National Speleological Task Force final Report of Study is expected about July 1972. The impact of the project on the caves is discussed in paragraph 29.

Two major quarries are in operation along the upper Stanislaus in the cave region— the Columbia Marble Quarry, and the Cataract Quarry of the Calaveras Cement Company, a division of Flinkote Corporation. The Columbia Marble Quarry, is located on a promontory just downstream from the junction with the South Fork, and is a visible scar in the steep, rock-walled canyon, especially from Parrott's Ferry road and bridge. The quarry is still operated periodically. The Cataract Quarry encompasses the steep limestone cliff in the upper Stanislaus between Wool Hollow Gulch and Cataract Gulch. At present, the quarry is still near the top of the cliff, but this will gradually be removed. Limestone is crushed in a new S7.500.000 crushing plant at the quarry, it is then slurried and conveyed by pipeline to the main pianc ac San Andreas. The crushing operation and the quarry is clearly visible from the Camp Nine Road. Immediately downstream from the damsite, but on the opposite (or Calaveras County) side is the Jefferson Lake Asbestos Company Quarry, also a division of Flinkote Corporation. Two large tailings piles are visible from the access road and Downstream Overlook.

Downstream from the dam, the Stanislaus River runs through a canyon in metamorphic rocks as far as Knight's Ferry and has no direct effect on interstream ground water in fractures. Below the Knight's Ferry area the river flows on sedimentary materials that contain an unconfined water table. Data on water levels in many wells are published by the U. S. Geological Survey. Such measurements indicate that ground water levels in the interstream areas, and even near the river, are generally higher than adjacent river levels, even in flood stage. This condition is related to surface irrigation practices, which include many feeder , and drainage wells. Much of the irrigation water is diverted from the Stanislaus River at Goodwin Dam, about 4 miles above Knight's Ferry, and transported downstream by canals on both sides of the river. Near the junction of the Stanislaus and San Joaquin Rivers ground water levels are close to surface, and many of the wells are designated as drainage wells.

23. Recreation resources. - The drainage basin includes a variety of outdoor recreation opportunities. The "High Sierra" and the forested Sierra slopes offer hiking, hunting, camping, skiing, rock climbing, cave exploring, and a limited amount of boating on the higher elevation small reservoirs. An unusual, much publicized, and fast-growing recrea­ tion resource is the Whitewater boating portion of the Stanislaus River between Camp Nine and the Parrott's Ferry Bridge. A popular recreation activity is driving for pleasure and sightseeing throughout the historic Mother Lode country, including the picturesque towns of Columbia, Murphy, . Angels Camp, Sonora, and Jamestown, all within twelve miles of New Melones Lake. Three scenic highways designated by the State of California, Ebbett's Pass (California 4) and Sonora Pass (California 108) and California 49, traverse the region. Calaveras Big Trees State Park lies in this area on the Ebbett's Pass Highway (35). California 49 crosses the future lake area and provides access to these towns and to other foot­ hill reservoirs. Some of these reservoirs, within short driving distance of New Melones Lake, are New Don Pedro, having a surface area at gross pool of 12,900 acres on 'the (a project of Turlock and Modesto Irrigation Districts and the City of San Francisco); New Hogan, with a surface area of 4,400 acres on the (a Corps of Engineers project); and Camanche with a surface area of 7,700 acres and Pardee (2,134 acre surface) on the (both East Bay Municipal Utility District projects). All of these reservoirs are popular outdoor recreation resources supporting increasing amounts of a variety of water-related outdoor activities. Due to lack of access and no public facilities, the existing Melones Reservoir receives very little recreational use. Additional discussion of recreational activities is presented in paragraph 27. Table 10 in paragraph 27a shows the existing recreational use of the Stanislaus River between Melones Reservoir and Camp Nine.

24. Land resources and uses. - In the higher elevations of the Stanislaus River drainage basin, virtually all of the land is within the Stanislaus National Forest and is administered by the U. S. Forest Service and remains in a relatively natural state. These lands are managed under a multiple use concept providing for timber harvest, recreation and a variety of other uses. A substantial portion of the privately owned forest land located between Highways 4 and 108 and between approximately the 3,000 and 6,000 foot elevations, is being developed as recreational subdivisions for vacation homes. Selective timber harvesting and construction of several small reservoirs have also influenced this area.

In the upper Mother Lode limestone region, limestone and marble quarries are in operation. Near the New Melones damsite is a large asbestos mine. Formerly worked gold mines and prospects are numerous in the area. In the Mother Lode foothill region, cattle raising predominates on unirrigated rangeland. There are many small towns, originally gold mining settlements, and a scattering of homes and cabins along most of the roads. Tourist or traveler-related services are important in the area. The relatively level areas between 1,100 and 1,300 foot elevations, near Highway 49 or near reservoirs and other attractive natural resources, are sought after by developers for "ranch-style" subdivisions. These typically are planned to have one-or-more acre parcels and are now being developed In the New Melones Lake area and near Camanche, New Hogan, and other nearby reservoirs. Large scale speculative land purchases have occurred In Calaveras County. Host significant of these are Circle XX, Diamond XX, Bar XX, Copper Cove and Baakdal amounting to a total of over 20,000 acres. Most of these acquisitions have been subdivided into 20 and 40-acre parcels and are not to be subdivided further. Uater supply for these areas is inadequate and it is not economically feasible to pump water from the nearby low level reservoirs to any of these areas except parts of Copper Cove and Baakdal. Water supply requirements for these areas are estimated to total about 13,000 acre-feet annually. The high water level and con­ servation yield from New Melones will make it possible for these areas to receive the required municipal water supply. Similar speculative / developments have occurred in Tuolumne County between the New Melones Lake project area and New Don Pedro Reservoir. The 14,000 acre area known as Dayharsh and about 3,400 acres of the Lake Don Pedro area may receive their water supply requirements of about 9,000 acre-feet annually from New Melones Lake. In Tuolumne County water supply is not as depen­ dent on New Melones Lake, for it may be possible to obtain water from New Don Pedro Reservoir on the Tuolumne River. Actions taken by Calaveras and Tuolumne Counties to handle further speculative subdivisions are discussed in paragraph 32c.

Downstream in the Central Valley, intensively developed irrigated agriculture predominates including pasture, deciduous fruit and nut orchards, a variety of crops, and poultry. Central Valley communities, which account for the major portion of the population in the region, are primarily economically dependent on agriculture.

25. Socio-economic conditions. - Historical events and a wealth of natural'" resources has had a pronounced Impact on the present sociological and economic condition. The initial motivation for population settlement was timber, cattle grazing, and prospecting for gold. Timber harvesting is at or near the sustained yield level so no great expansion is possible in that direction. Agriculture, particularly cattle raising, is a major source of income but because of the high tax on land, it is expected to decrease in the foreseeable future. Also, unless the price of gold Increases, further income from this source is not likely. ^Generally the economic condition in Tuolumne and Calaveras counties is xn 1970 the unemployment rate in Tuolumne County ranged from 9.9 percent in July to 19.7 percent in December with an average of 13 percent. i/ In Calaveras County for 1970 the unemployment race ran fiuiu 4.7 percent in June to 12.1 percent in December. High school graduates cannot find jobs and are leaving home...... n»n t^-i many people are living at or near subsistence level. Median Income in Tuolumne County was $5,602 and $5,524 in Calaveras County (36) (37), while the per capita income is about $3,000 in Tuolumne County and $2,640 in Calaveras County (62). According to the Tuolumne County General Plan, "All this has the effect of inducing slums and blight, causes social problems ami works against promotion of new industry, new settlement and capital investment. It also depresses the tax base on which the county depends for providing the necessary services."

/ Tourism to the recreational and historical areas in these two counties is increasing. Some of the attractions are: Angels Camp where the annual frog jump is held; Mark Twain's cabin; mines, which in the Angels Camp area produced over $100 million in gold; Carson Hill Mine which produced the largest gold nugget ever found in the United States and the largest mass of gold taken in California, weighing 195 pounds troy and valued at $43,534; whitewater boating; unique geological features such as natural bridges and Moaning Cave; and numerous lakes (37).

The Tuolumne County General Plan also stated that "Recreation . . . in the next few decades will equal or surpass the total annual sales of ail primary Indus tiy :**— Thu General Plans for Calaveras and Tuolumne ~ counties Indicate that the towns of Sonora, Jamestown, Columbia and Angels Camp will experience compound growth rates of 2.7 percent, 2.5 percent, 3.5 percent and 5 percent, respectively, for the next 10 to 20 years. Since the public has been aware of the New Melones Lake project for many years, this growth rate to some extent is in anticipation of the completed project and therefore the project when completed is not expected to greatly increase this rate. As an example of this anticipation the Angels Camp Master Plan (in Calaveras County General Plan) (37) shows a parkway extending from Angels Camp to the new lake.

Both counties are cognizant of the importance of their natural and historical resources and the economics of recreational developments. They have accordingly set forth measures which will insure that tourist-related developments do not endanger these resources. Measures include building codes, restoring historical areas, tearing down old abandoned buildings, and zoning land for urban and second home development. It seems, there­ fore, that the sociological and economic impact of the project on this area will be consistent with this general trend. Further discussion is presented in paragraph 32. SECTION I I I - ENVIRONMENTAL IMPACT OF THE PROPOSED ACTIONS

The environmental impact associated with several aspects of the project is discussed in the following paragraphs. Each aspect is dis­ cussed in three parts:, (a) changes or conversions; (b) beneficial and detrim ental aspects; and (c ) rem edial, p ro te c tiv e , and m itlg a tiv e measures

26. Effect on hydrology.

a. Changes or conversions - The seasonal distribution of flows belcw the dam w ill be altered, with floodflows reduced and low flows augmented. With the flood control storage provided by the project, releases from New Melones Dam in excess of 8.000 cubic feet per second are expected to occur less frequently than once every 1UU yearSj on the average (lass than one pe.lunit clrsilCE! Of dccurrlng in any one year). The effect the project w ill have on flows in the Stanislaus River during non-flood periods w ill depend to a large extent on where the new conser­ vation yield developed by the project is used. Detailed estimates of post-project flows are affected by many factors, but some preliminary estimates of what flows might occur with New Melones project in operation are given in table 8. The information presented in tables 8 and 9 is based on the historical hydrologic cycle records (19^1 to 1946) and indicates what would have occurred in past years i f New Melones had been in operation. For a comparison, the existing flews are shown in parentheses. Information presented in table 9 is for comparitive purposes only and shews flows expected if New Melones conversion yield is not diverted as planned by Knights Ferry Diversion Dam and the East Side Division of the Central Valley Project. New Melones Below Month Powerhouse Knights Ferry* At Ripon* (values are in cubic feet per second)

» A - AVI2 RAGE MONTHLY FLOWS;•

Jan 572 ( 742) 197 ( 370) 312 ( 485) Feb 907 (1,446) 384 (1,199) 574 (1,389) Mar 950 (1,791) 424 (1,654) 574 (1,804) Apr 1,378 (2,565) 135 (1,582) 310 (1,757) May 2,304 (3,846) 282 (2,409) 412 (2,539) Jun 2,511 (2,608) 297 (, 920) 522 (1,145) Jul 2,428 (1,243) 132 ( 30) 347 ( 245) Aug ?»120 ( 894) 130 ( 0) 285 ( 155) Sep 1,239 ( 566) 132 ( 0) 307 ( 175) Oct 717 ( 430) 190 ( 0) 350 ( 160) Nov 367 ( 329) 194 ( 0) 304 ( 110) Dec 382 ( 510) 223 ( 87) 313 ( 177)

B - AVERAGE MONTHLY FLOWS - FIVE LOW MONTHS:

Jan 198 ( 315) 100 ( 0) 215 ( 115) Feb 150 ( 330) 112 ( 0) 302 ( 190) Mar 261 ( 560) 100 ( 89) 250 ( 239) Apr 1,042 ( 979) 105 ( 39) 280 ( 214) May 1,606 (1,253) 125 ( 0) 255 ( 130) Jun 1,702 (1,105) 80 ( 0) 305 ( 225) Jul 1,347 ( 719) 92 ( 0) 307 ( 215) Aug 1,021 ( 551) 85 ( 0) 240 ( 155) Sep 654 ( 378) 87 ( 0) 262 ( 175) Oct 510 ( 363) 150 ( 0) 310 ( 160) Nov 315 ( 300) 160 ( 0) 270 ( 110) Dec 260 ( 301) 157 ( 0) 247 ( 90)

C - AVERAGE MONTHLY FLOWS - FIVE HIGH MONTHS:

Jan 1,688 (1,790) 511 (1,599) 626 (1,714) Feb 2,516 (3,270) 1,283 (3,055) 1,473 (3,245) Mar 3,282 (3,715) 1,643 (3,605) 1,793 (3,755) Apr 2,573 (4,290) 199 (3,300) 374 (3,475) May 3,856 (6,445) 893 (4,890) 1,023 (5,020) Jun 4,292 (4,908) 1,103 (2,994) 1,328 (3,219) Jul 3,185 (1,511) 245 ( 136) 460 ( 351) Aug 2,895 (1,038) 247 ( 0) 402 ( 155) Sep 2,219 C 658) 238 - ( 0) 413 ( 175) Oct 1,140 ( 451) 200 ( 0) 360 ( 160) Nov 433 ( 404) 211 ( 0) 321 ( 110) Dec 641 (1.179) 367 ( 434) 457 ( 524) * These flows reflect the release of water for minimum flows needed for fish and flows needed for water quality purposes. TABLE 9 - PRELIMINARY ESTIMATES OF FLOWS IN STANISLAUS RIVER WITH NEW MELONES IN OPERATION AND WITH NO DIVERSION OF NEW CONSERVATION YIELD FROM THE STANISLAUS RIVER* (Existing flows shown in parentheses for comparison) (Flows are in cubic feet per second)

New Melones Below Month Powerhouse Knights Ferry At Ripon

• A - AVERAGE MONTHLY FLOWS •

Jan 572 ( 742) 515 ( 370) 630 ( 485) Feb 907 (1,446) 1,026 (1,199) 1,216 (1,389) Mar 950 (1,791) 901 (1,654) 1,051 (1,804) Apr 1,378 (2,565) 502 (1,582) 677 (1,757) May 2,304 (3,846) 828 (2,409) 958 (2,539) Jun 2,511 (2,608) 998 ( 920) 1,223 (1,145) Jul 2,428 (1,243) 994 ( 30) 1,209 ( 245) Aug 2,120 ( 894) 954 ( 0) 1,109 ( 155) Sep 1,239 ( 566) 432 ( 0) 607 ( 175) Oct 717 ( 430) 292 ( 0) 452 ( 160) Nov 367 ( 329) 218 ( 0) 328 ( 110) Dec 382 ( 510) 293 ( 87) 383 ( 177)

B - AVERAGE MONTHLY FLOWS - FIVE LOW MONTHS:

Jan 198 ( 315) 126 ( 0) 241 ( 115) Feb 150 ( 330) 146 ( 0) 336 ( 190) Mar 261 ( 560) 119 ( 89) 269 ( 239) Apr 1,042 ( 979) 125 ( 39) 300 ( 214) May 1,606 (1,253) 135 ( 0) 265 ( 130) Jun 1,702 (1,105) 87 ( 0) 312 ( 225) Jul 1,347 ( 719) 129 ( 0) 344 ( 215) Aug 1,021 ( 551) 115 ( 0) 270 ( 155) Sep 654 ( 378) 94 ( 0) 269 ( 175) Oct 510 ( 363) 160 ( 0) 320 ( 160) Nov 315 ( 300) 170 ( 0) 280 ( 110) Dec 260 ( 301) 180 ( 0) 270 ( 90)

C - AVERAGE MONTHLY FLOWS -F IV E HIGH MONTHS:

Jan 1,688 (1,790) 1,742 (1,599) 1,857 (1,714) Feb 2,516 (3,270) 2,784 (3,055) 2,974 (3,245) Mar 3,282 (3,715) 3,139 (3,605) 3,289 (3,755) Apr 2,573 (4,290) 1,525 (3,300) 1,700 (3,475) May 3,856 (6,445) 2,368 (4,890) 2,498 (5,020) Jun 4,292 (4,908) 2,540 (2,994) 2,765 (3,219) Jul 3,185 (1,511) 1,627 ( 136) 1,842 ( 351) Aug 2,895 (1,038) 1,618 ( 0) 1,773 ( 155) Sep 2,219 ( 658) 1,284 ( 0) 1,459 ( 175) Oct 1,140 ( 451) 700 ( 0) 860 ( 160) Nov 433 ( 404) 304 ( 0) 414 ( 110) Dec 641 (1,179) 637 ( 434) 727 ( 524) * This is a preliminary estimate based on a simple "with" or "without diversion concept. If no diversion is decided upon, detailed operation studies could result in a different pattern of flows depending upon alternative uses of water. Study based on historical flow records, 1921 to 1946. Average accretions to the Stanislaus River from Orange Blossom Bridge to the mouth have increased from 183 cubic feet per second in 1954 to 395 cubic feet per second in 1958 during the irrigation season (March through October) (34).

The existing floodway of the Stanislaus River downstream from Goodwin Dam w ill be maintained by the Corps of Engineers to a flood carrying capacity of at least 8,000 cubic feet per second. This is approxlmately the capacity of the floodway as it exists at present, so no significant physical alterations to improve flood carrying capacity w ill be required.

The New Melones project w ill provide flood protection to 35,000 acres of highly developed agricultural land along Stanislaus River and to suburban areas of Oakdale, Riverbank, and Ripon. Together with other projects on the lower San Joaquin and Tuolunne Rivers, New Melones w ill aid substantially in reducing flooding along the lower San Joaquin River and in the Sacramento-San Joaquin Delta. It w ill assist _in_iirafc£ctiiig_ 235.000 acres of intensively developed agricultural lands, military .lfim m il-ens, and industrial and suburban areas in the vicinity of Stockton. If New Melones Reservoir had been completed and in operation during the 1955-1956 flo o d s , i t would have prevented a l l o f the $1,928,000 flood damages that occurred along Stanislaus River below the existing dam. During the Decesber 1964 and April-July 1967 floods, the project would have prevented flood damages estimated at $1,623,000 an^ $743,000, respec­ tively. If a project design flood should occur, it is estimated that the project would prevent flood damages of $4.400.000 along Stanislaus R iver, and, in conjunction with the proj e c t Ulfflci l u ib h u l iI uii on the lower San Joaquin and Tuolunne Rivers, would contribute towards preventing flood damages of S-46t000.000 alone the lower San Joaquin River and in the San Joaquin Delta (11).

An average of 285,000 additional acre-feet of conservation yield, measured at the dam, and including iq> to 70,000 acre-feet for water quality purposes w ill be available each year. Most of the water released for irrigation and other project purposes w ill be used for power generation and conversely water used for generation of power w ill at times be used for other purposes. About 430,000,000 kilowatt-hours of energy could be gen­ erated per year, on the average. The existing Pacific Gas and Electric Company's Melones pcwerplant, having an in s ta lle d capacity o f 26,000 kllcwattG^ would be made inoperable by the project.

The average annual flew of the Stanislaus River at the New Melones damsite is 1,130,000 a c r e -fe e t. Of th is amount, an average o f 535,000 acre-feet per year is currently diverted for irrigation in the Stanislaus River Basin. Tentative projections by the Bureau of Reclamation indicate that the annual requirements for local basin use w ill increase by about 100.000 acre-feet. The long-term average of the 70,000 acre-feet for water quality purposes Is about 35,000 acre-feet annually. About 150,000 acre-feet of the conservation yield would remain available for export to other areas on the east side of the San Joaquin Valley, Including San Joaquin and Stanislaus Counties. Although actual quantities and areas In which this water w ill be used cannot be determined until water service contracts are executed, It is anticipated that about 10Z would be used to meet municipal and industrial demands. Abnut 75* __ would be used as a supplemental-supply to areas now under ir r ig a tio n 'tcm llevlate present ground water overdraft or provide a fu ll irrigation siq>ply (see paragraph 4). Any remaining supply would be used to irrigate new lands not new under irrigation. Using an average requirement of 3 acre-feet per acre, this would mean that a maximum of only about 7,500 acres of new land would be put under irrigation.

b. Beneficial and detrimental aspects. - The high degree of flood protection that would be realized from this project would safeguard human life , personal property, and residential and agricultural lands and improvements that presently exist downstream from the damsite. Down­ stream development of valuable agricultural and residential land would be stimulated with resultant Increases in agricultural production. This Is further discussed in paragraph 32. However, even without a flood pro­ tection project such as New Melones Lake, development would s till occur downstream. This would result in even greater damage and losses than presently would occur In the event of a major flood. The irrigation dis­ tricts in the area have expressed interest in constructing their own version of an enlarged Melones Dam. This could provide some flood protection and additional irrigation supply.

The additional pewer developed from the project w ill help meet the Increasing need for power in the Central Valley. Since hydroelectric power is generated without air, water, or thermal pollution, it Is signi­ ficant in that an average of 430,000,000 kilowatt-hours of energy w ill be generated annually without the need for utilizing fossil fuel or nuclear methods w ith th e ir attendant environmental problems.

The estimated 285,000 acre-feet of new conservation yield produced annually by the project w ill be used to supplement existing supplies within the Stanislaus River Basin as required by the authorization (4), and to the extent this new water is surplus to the local needs, including water quality control, it w ill be available for export from the basin to serve other water-deficient areas of the San Joaquin Valley. The net value o f the new conservation y ie ld is estim ated by the Bureau o f Reclama­ tion to be $3,610,000 annually.

Up to 70,000 acre-feet of water would be available annually for the purpose of maintaining water quality in the Stanislaus River and San Joaquin R iver. c. Remedial, protective, and mltigative measures. - Flood protection, power generation, and irrigation water supply are beneficial project purposes. Other effects of changes in hydrology are related to specific items discussed in succeeding paragraphs, and m ltigative and protective measures for such effects are discussed in those paragraphs.

27. Effect on recreation.

a. Changes or conversions. - New Melones Lake w ill have a surface area about seven times larger than the existing Melones Reservoir and therefore would sustain significantly more public recreation. Public access developments w ill be provided where none are available now. The U. S. Bureau of Reclamation w ill be responsible for the management of recreation areas at the new lake. It is estimated that New Melones Lake w ill attract about 320,000 recreation days annually within three years after project completion and that future use w ill grow to a high of 4,000,000 recreation days annually. New Melones project is in general accordance with the California Outdoor Recreation Plan. The type of rec­ reation use which the river provides is very different from that which New Melones Lake w ill provide. According to the Environmental Defense Fund (s e e EDF comment number 36 in appendix A ), the recrea tio n a l days annually attributed to commercial rafting trips may have increased from 9,000 in 1970 to 13,000 in 1971. In the absence of New Melones Lake, recreation day use of the 16 miles of river within gross pool area w ill continue to Increase. The level of use at which this resource can ulti­ mately support without damage from overcrowding is not known. The precip­ itous canyons, lack of sanitary fa cilities, and limited access and parking areas may curb the use In this area and thereby protect it somewhat from overuse. A tabulation of estimated existing recreation use on the Stan­ islaus River between Melones Reservoir and Camp Nine is shown in table 10.

TABLE 10 - EXISTING RECREATION USE OF STANISLAUS RIVER BETWEEN MELONES RESERVOIR AND CAMP 9

Estimated Recreation A c tiv ity Days Annually (1970)

Commercial r a ft trip s 9,000 A/ Private rafting & kayaking 10,000 Fishing on river 26,000 B/ Miscellaneous (gold mining, hiking, & sightseeing) 15,000

TOTAL 58.000

A/ Includes 2,000 recreational days annually in the river before and after a raft trip (38). B/ Based on estimates presented in Bureau of Sport Fisheries and W ildlife report (3). The reach of the river between Camp 9 and Parrott's Ferry Bridge is considered to be a Class IV whitewater area, "very good without being unduly hazardous." It is classed as Group A (best) for "short river sections for canoeing, kayaking, and rafting" and is the most heavily used whitewater river in California (39). Th® importance of this white- water resource to a growing segment of people participating in whitewater oriented recreation is recognized. Excluding the Stanislaus River, there are about 300 miles of Class IV whitewater remaining in California (39).

Upstream from Camp Nine Powerhouse on the Middle Fork o f the Stanislaus River, releases from Beardsley Dam through the diversion tunnel to Can? Nine Powerhouse for pcwer generation have, since 1958, been responsible for providing Important flows during much of the year that are necessary for whitewater boating. Before construction of Beardsley Dam, adequate, flows existed only for relatively short peroids of time.

At times of high water (gross pool elevation 1,088 feet), the reser­ voir w ill inundate all of this reach. At times of average summer elevation (recreation pool elevation 1,021 feet), a ll except 1.2 miles of this reach w ill be inundated. At times of very low water (inactive pool elevation 808 feet), most of this reach w ill flew naturally. Because of lack of a v a ila b ilit y o f enough m iles o f whitewater except during "dry c y cles" and unattractive appearance of the barren and wave lapped canyon sides after the future reservoir rises to gross pool, commercial whitewater rafting operators advise that no commercial whitewater tours would be attempted after the new reservoir is filled .

The stream fishery between Melones Reservoir and Camp Nine would be inundated and replaced by a lake fishery. Th's is discussed in para­ graph 31.

Recreational use of the Stanislaus River below Goodwin Dam is limited by low flows, particularly during summer months when flows are intermittent. Increased flows in the river below New Melones Dam would enhance the rec­ rea tion p o te n tia l fo r a c tiv itie s such as kayaking, canoeing, swimming, fishing and sightseeing (40). Insufficient public access is also a serious problem lim iting existing recreation use on the lower Stanislaus. One of the objectives of the plans being developed for environmental protection and enhancement along the lower Stanislaus would be provision of public access. The water quality lnprovement which New Melones Lake w ill provide would further improve the river's desirability for recreation. Loss of 16 miles of upstream trout fishery w ill be mitigated and offset by enhancement o f the anadromous fis h e ry and the establishment o f a trout fishery below Goodwin Dam due to release of colder waters and improved flews from New Melones Lake (3 )(8 ). Fishing for anadromous fish down­ stream would be greatly inproved and is further discussed in paragraph 31. Recreational use at existing Melones Reservoir is limited and was about 45.000 recrea tio n days annually in 1970. Recreation uses at New Melones Lake w ill be many and varied as shown In table 11 belcxr. These estimates are based on the pattern of uses observed at Pine Flat Lake on the from 1966 to 1968 (41). The percentages shown represent the proportion of visitors expected to participate In each activity.

TABLE 11 - ESTIMATE OF RECREATION USE PATTERN AT NEW MELONES LAKE

Boating - 502 Fishing - 402 Sightseeing - 302 Water skiing - 252 Picn ick in g - 302 Camping - 102 Swimming - 202 (and others)

b. Beneficial and detrimental aspects, - Inundation of 16 miles of river due to New Melones Lake w ill largely eliminate existing whltewater boating, stream fishing, gold panning, hiking, and picnicking along this reach of stream. However, it w ill make the area more accessible to the public for boating, sightseeing and picnicking.

The overall inpact on recreation w ill be a significant increase in most recreation activities and provision for new activities such as in-lake fishing for both warm water and cold water species, increased salmon and steelh ead fis h in g downstream from Goodwin Dam as w e ll as Increased boating and other recreation activities. Tours of caves in the project area are also a possibility.

Recreation development would benefit large numbers of people from the Central Valley and East Bay metropolitan areas. Modern landscaped facilities w ill be provided for the recreationists at the lake, including access roads, parking lots, camping and picnicking facilities, restrooms, and showers. Emphasis w ill be placed on preserving the natural setting. This w ill involve using materials and structures that w ill be harmonious with the surroundings. During construction, environmental disturbance w ill be minimized. Further discussion of this sibject can be found in paragraphs 30 and 34.

Releases from New Melones pcwerplant would result in short-term fluctuations that could Increase the maintenance costs of boat docking and servicing facilities in Tulloch Reservoir.

During project construction, noise, dust, and other activities associ­ ated with construction w ill cause some disturbance to recreationists in the area. This would be minor considering the overall recreational activities and would only be for a relatively short period of time. Also, construction activities would be limited primarily to the area where the dam Is being constructed.

c. Redmedlal, protective, and raitigative measures. - Whitewater boating access points at Camp Nine and Parrott's FerryBridge w ill be maintained at a ll times during road relocations, permitting the white- water activity to continue unchanged in this primary reach until the water level in New Helones Lake exceeds 850 foot elevation. Below Parrott's Ferry Bridge, the secondary whitewater reach takeout point just above existing Highway 49 (Melones) Bridge w ill be maintained until the water level in New Melones Lake exceeds the 750 foot elevation. The interim Corps of Engineers' recreation site near existing Highway 49 Bridge w ill also be maintained until inundated.

The problem of finding a reasonable method of mitigating for white- water has received intensive study and w ill continue to be investigated. Several approaches have been and are presently being investigated including the feasibility of developing the upstream reaches and tributaries of the Stanislaus River for whitewater recreation. Preliminary studies indicated that there might be potential for significant mitigation in a seven and one half mile reach on the Middle Fork of the Stanislaus River above the project. Possible means for inproving flows in the Middle Fork by means of releases from Beardsley Dam and by constructing improved access to the potential whitewater reaches were investigated. Short reaches of the North Fork and Middle Fork were also evaluated for whitewater use, primarily kayaking (42). As a result of discussions and evaluations made by a nunber of persons involved in whitewater commercial rafting and conparlsons with whitewater resources elsewhere, it is now apparent that there is no feasible opportunity available on the Stanislaus River or its tributaries uostrefl™ t-he project area to provide any means for mitigating the loss of the whitewater rommerrial raftine use. Downstream from Goodwin Dam there is approximately 4 m iles o f r iv e r that has the potential for whitewater kayaking, including whitewater slalom competition, if adequate flows and access improvements are provided. A field test of this reach was conducted by a group of expert kayakers at flows of 350 and 600 c.f.s. The results of this test are being analyzed and a specific. proposal for the use of this reach of river by kayaks is being developed. Development of this reach for whitewater boating could offer partial mitigation for whitewater loss upstream. U. S. Bureau of Reclamation's proposed Knights Ferry Diversion Dam for diverting water to the East Side Division is located within this 4 mile reach. Possibilities for alternative whitewater areas on other rivers such as the Tuolumne River jgaj^exist. One possible area that has been suggested is the Tuolumne River between the Lumsden Bridge crossing and New Don Pedro Reservoir. Whitewater boating users of this reach report that this reach could be improved i f additional flows could be made available. This reach may however provide a different class of vhitewater than Is In the reach to be Inundated on the Stanislaus River. Studies of this are continuing. Close coordination with vhitewater interests is continuing in searching for mitigatory means. Implementation of any of these plans would be contingent on economLc and engineering fe a s ib ilit y as w e ll as coordina­ tion with other concerned agencies and interests and necessary approval from higher authority.

To protect the natural resources of the lake and facilitate the large number of re creationists that are anticipated, extensive recreational fa cilities are planned. A master plan to guide the development and manage­ ment of public use facilities at the project is currently being prepared. One of the objectives of this plan is to minimize any adverse environmental impact from recreation development and to preserve scenic, biological, and recreational resources of the project area.

28. Effect on historical and archeological features.

a. Changes or conversions. - Some old buildings, ruins, and aban­ doned mines dating back to the C a lifo rn ia gold rush days o f 1849 and 1850 would be inundated. These include the ruins of the Melones gold smelting m ill, Robinson's Tavern and Robinson's Ferry at Melones, Parrott's Ferry, Abbott's Ferry, and several small mines and m ills. At least 50 archeological sites w ill also be inundated (30). These are discussed in paragraph 21 and 22.

b. Beneficial and detrimental aspects. - The caves and historical and archeological features located below gross pool would be lost except for those artifacts which can be removed prior to inundation, and those such as concrete foundations that can withstand prolonged inundation. The National Park Service is conducting a program of archeological inven­ tory and salvage (51). Some of these artifacts recovered w ill be displayed at the project for public information and interpretation of the area's archeological resources. Others w ill be retained for study and educational purposes by colleges and universities.

c. Remedial, protective, and ndtigative measures. - Preliminary surveys and two years of excavations have been conducted under the direction of the National Park Service to locate and remove archeological artifacts. The National Park Service has developed a 5-year program for archeological and historical investigation and preservation at the project.

Existing historic landmark designations at Parrott's Ferry and Robinson's Ferry are planned to be relocated near the abutments o f the new bridges to be constructed as a part of the road relocation work for . the P a r r o tt's Ferry Road and Highway 49. 29. Effect on geology and ground water.

a. Changes or conversions. - There are numerous caves in and adjacent to the project area. These are located In an extensive limestone region near the upper Stanislaus arm of the reservoir. The National Speleological Society Task Force reports more than 70 limestom» caves and two natural bridges in the vicinity of New Melones Lake, and there are probably other caves in the area which have not yet been explored (33). The New Melones Lake w ill Inundate 10 of these caves. The largest cave to be inundated is McLeans Cave. New Melones project w ill make 10 of the caves (seven large and three lesser caves just above gross pool) and the two natural bridges readily accessible to the public. All caves in the project area w ill be more accessible to the public. One of the natural bridges is located at gross pool elevation and may be sii>jected to wavewash when the reservoir is at its highest stages. The other natural bridge is above gross pool and outside of the presently approved project boundary and is shown in photo 6. Commercially operated Moaning Cave is above gross pool. The National Speleological Society has advised that the lake at gross pool "w ill seriously affect air flow and/or hydrology in the lcw er le v e ls o f Moaning Cave, since a la rge volume o f water now flews southwest at about the 1,100 foot level there" (3**). The Mouth o f Moaning Cave is at about 1,690 fo o t e le v a tio n and has not been explored to more than a depth of about 450 feet and therefore, the effect of possible changes in air or water flow at the 1,100 foot level have not been evaluated. Corps of Engineers geological studies indicate that the limestone formation does not extend downstream from the dam or outside of the drainage area in a manner that would permit significant percolation of stored water out of the reservoir.

The unweathered bedrock in the project area is essentially impervious and contains water only in fractures. The rocks, therefore, do not contain a water table similar to that of pervious material, but rather levels that are erratic, indicating that fractures are not interconnected. The reser­ voir would raise the ground water in the bedrock area to about a level that presently exists during the winter.

Above Parrott's Ferry the main and south forks of the Stanislaus River run for about three miles across several limestone formations, which extend southeastward through the community o f Columbia and end a few m iles southeast of the tewn of Sonora. Most of the Colunfcia-Sonora area is at elevations above 2,000 feet. The existence of several large springs indicates that ground water levels are shallow, and that the ground already is saturated above the New Melones gross pool elevation of 1,088 feet. The Stanislaus River shows no evidence of water loss in the reaches floored with limestone. Leakage from the New Melones Lake, therefore, is not considered to be significant. Ground water levels In areas where lands are Irrigated ate considerably higher than the average monthly water levels of the river. Even under high w ater flows such as shown in ta b le 8 that w ill raise the stream level to a maximum of about 10 feet, ground water levels w ill be higher. It has been concluded that changes in downstream Stanislaus River flows w ill not significantly affect existing ground water conditions.

The project area has experienced little seismic activity in historical times. The nearest known active fault is the Owens Valley fault about 70 miles east of the project. The New Melones Lake site is subject to 4 tremors f rom frpnuant -earthquakes of relatively small magnitude having epicenters within 150 miles of the site. No data arp~1 ah I p - naTTnEgft- sity of these tremors at the site. A program has been established for seismic monitoring or tne project area beforeT during and aft^r construc­ tio n Of New Melones Dam. “ ‘ ’

b. Beneficial and detrimental aspects. - The limestone caves and natural bridges located above the gross pool elevation w ill be made more easily accessible to the general public. This presents an opportunity for development of a unique educational recreation feature. If, however, the caves are not protected from uncontrolled public access, the delicate formations which they contain would probably be vandalized. Caves located below the gross pool level may be damaged by periodic inundation.

Ground water changes in the vicinity of the reservoir resulting from the project are not expected to have either beneficial or detrimental e ffe c t s .

c. Mitigative and protective measures. - The National Speleological Society and Yokut Wilderness Group of the Sierra Club have requested preservation of remaining caves around the project (33)(43). This matter has been brought to the attention of the National Park Service and other agencies who indicate that the limestone caves and natural bridges may be of national significance. Public activities connected with cave use and appreciation of natural bridges and other geological features w ill be additional recreational activities at the new lake. Measures for protection and public use of these geological resources w ill be Included in the master plan for the lake. To prevent vandalism, entrances of caves may be gated. Consideration is being given to relocating cave­ dwelling biological specimens that w ill be affected by the project to other caves.

30. Effect on water quality.

a. Changes or conversions. - Alteration of the existing Stanislaus River hydrology w ill affect water quality in the Stanislaus River below the project and in the downstream San Joaquin River and Delta system. One effect w ill be the alteration from the seasonal flushing arHnn ° f h igh-j>eak-v±TTter flw s to sustained flews, that are release dt-nrnnfnrn. to flood control objectives, irrigation, power and recreation demands, and to achieve specific water quality and fishery objectives. During lew flow periods, fresh water flews are the dominant flushing force in the upper portion of the estuary, while tidal action provides the primary force flushing pollutants from the lewer estuary. Recent studies have shown, hewever, that higft winter fresh water flows provide important flushing action throughoufThg-pslra-estirffiy;— Pollutants caTKe controlled by restricting discharges, and progress is being made by communities in accomplishing this objective. However, a ll pollutants cannot be controlled at the source, so substantially reducing high winter flows could increase quality problems (44). Water stored for the purpose of water quality enhancement w i l l be released when necessary to maintain to ta l d issolved solids (TDS) concentrations below 500 mg/1 in the San Joaquin River at Vernalls and a minimum of 5 mg/1 of dissolved oxygen in the Stanislaus River. Additional improvement to Stanislaus River water quality would result from compliance with the California Regional Water Quality Control Board objectives for waste discharges (18), which are as follows:

"Median dissolved oxygen concentrations in the main water mass of streams and above the thermodlne in lakes shall not fa ll belor 85 percent of saturation concentra­ tion, and the 95 percentile concentration shall not fa ll below 75 percent of saturation concentration as a result of waste discharges. Additionally, dissolved oxygen at any location shall not fa ll below 5 mg/1 at any time as a result of waste discharges; when natural factors cause lesser concentrations, then controllable water quality factors shall not cause further reduction."

The Bureau of Sport Fisheries and W ildlife's (BSFW) acceptable dissolved oxygen concentrations (45) are compared with California Regional Water Quality Control Board (CRWQCB) objectives below. TABLE 12 - TEMPERATURE AND DISSOLVED OXYGEN RELATIONSHIPS FOR STANISLAUS RIVER BELOW GOODWIN DAM

Acceptable Dis- Dissolved Oxy- Temperature solved Oxygen D issolved Oxy- gen at 85% Obj ec tiv e O bjective gen at 100% saturation Period (BSFW) (BSFW) saturation (CRWQB)

(values - ppm - are parts per million)

1 Oct-31 Mar 42-60*F. 10 to saturation 10 to 12,8 ppm 8.5 to 10.7 ppm

1 Apr-31 May 50-60* F. 7 to 9 ppm 10 to 11.3 ppm 8.5 to 9.6 ppm

1 Jun-30 Sep 50-65*F. 7 to 9 ppm 9.5 to 11.3 ppm 8.1 to 9.6 ppm

Although the levels of dissolved oxygen indicated are a recent change from previous information indicating that only 5 ppm (or mg/1) was the minimal desirable level, the State of California in a letter dated 21 July 1971 has confirmed that the higher levels are the objective to be met in maintaining Stanislaus River water quality for a ll beneficial uses (indicated in colusn five of table 12 above)•

The procedure used for detecmining the need for water quality control flows are presented in some detail in the Public Health Service report (10). To determine flow requirements for controlling the concentration of total dissolved solids at Vernalis, hydrologic data developed by the U. S. Bureau of Reclamation was used. The median IDS at Tulloch Reservoir after fu ll operation of the Tri-Dam Project was reported to be 41 mg/1 with a range o f 33 to 65 mg/1. Water released from Goodwin Dam o r stored at New Melones was assumed to hold a TDS concentration o f 50 mg/1.

To determine flew regulation requirements to control the concentration of dissolved oxygen, projections were made for domestic waste loads on a per capita basis and industrial population.

Proposed releases for fish (table 14) were assumed to be in the stream prior to water quality control releases. Annual draft on storage for water quality control is shown in table 13. TABLE 13 - ESTIMATED ANNUAL DRAFT ON STORAGE FOR WATER QUALITY CONTROL <|l6!T

Year Mean Range

1 - TOTAL DISSOLVED SOLIDS DRAFT ON STORAGE X-!

*1978 10(900 acre-feet 0 - 48,500 acre-feet 2000 10,900 " " 0 - 48,500 " " 2025 10,900 " " 0 - 48,500 " " 2050 10,900 " " 0 - 48,500 " " 2075 10,900 " " 0 - 48,500 " "

2 - DISSOLVED OXYGEN DRAFT ON STORAGE:B/

*1978 240 acre-feet 0 - 2,000 acre-feet 2000 440 " " 0 - 4,000 " 2025 4,100 " " 0 - 11,500 " " 2050 13,300 " " 1,500 - 26,500 " " 2075 25,100 " " 8,500 - 33,500 " "

3 - TOTAL DRAFT ON STORAGE:

*1978 11,100 a c re -fe e t 0 - 48,500 a c re -fe e t 2000 11,300 " " 0 - 48,500 " " 2025 15,000 " " 4,000 - 48,500 " " 2050 24,200 " " 16,500 - 50,000 " " 2075 36,000 " " 29,500 - 58,500 " "

4 - TOTAL RELEASE FROM STORAGE: C/

*1978 15,500 a c re -fe e t 0 - 66,000 acre-feet 2000 15,700 " " 0 - 66,000 " " 2025 19,400 " " 4,000 - 66,000 " " 2050 29,000 " " 16,500 - 67,500 " " 2075 41,200 " " 29,500 - 76,500 " " a TDS releases may be needed In any irrigation month (February through November) but are largest and occur most frequently in April through September.

B/ Months when DO releases are needed: 1978 and 2000 - August; 2025 and 2050 - July through September; 2075 - June through September. (These releases are in addition to releases for TDS control.)

C/ Includes all Tri-Dam spills in excess of fish releases that can be used for water quality control. It also includes a portion from storage needed to bring mean weighted TDS concentration up to "with­ out” project conditions.

In the PHS report 1970 was used as the first year of the project. Releases made fo r enhancement o f d issolved oxygen are projected to maintain a minimum concentration of 5 mg/1 in 10 out of 11 years until the year 2075 and they would maintain over 4,5 mg/1 for the 1 in 100 year low flow. The total water quality releases that were projected for total dissolved solids control, according to the Public Health Service report, would be sufficient to maintain a mean monthly TDS concentration below 500 mg/1 at Vemalls at all times during the irrigation season. It was assumed that the quantity of water needed for TDS control would not change with time because it was assumed that the conditions of flow and TDS at Vernalis would remain constant (10). Subsequent to release of the Public Health Service report, uncertainties about the future hydrology of the San Joaquin River Basin have developed and therefore table 13 should be used only as a rough indication of possible releases, particularly as they relate to TDS control of 500 ppm at Vernalis (46).

Based on recent data (46) it appears that the trough of the San Joaquin Valley has been functioning as a salt trap_with the totfll gtiarn-^y "—' dissolved s o lid s e itte rlttft v a lle y aynt-onTT^-trifl nflflqiderably more than tHat accountable for in the outflow of the San Joaquin River at Vernalis.^ If the Salt bdlld-up~continues, adverse effects on municipal, industrial and agricultural users in the San Joaquin Valley w ill continue to increase. Release of water for quality control purposes, Installation of land drainage fa cilities or other means w ill be required to alleviate the problem and maintain the productive capacity of the valley. Thus, it is expected that the rate of dissolved solids leaving the San Joaquin River Basin must be increased to equal or exceed the rate of mineral solids input (46). If the objective TDS level of 500 ppm in the San Joaquin River at Vernalis cannot be maintained by releasing up to 70,000 acre-feet from New Ilelones Lake, a master drain system or other remedial measures, such as releases from the proposed East Side Division, may eventually be required.

New irrigation water supply w ill be developed creating new irrigation waste return flows within the San Joaquin and possibly Tulare Basins. If the irrigation supply were released to the Stanislaus and the San Joaquin Rivers and diverted from the Delta via existing pumping facilities, total dissolved solids concentrations would be maintained at levels substantially less than those presently occurring during periods of high water use.

The power production w ill ^ t have any direct effects upon water *4---- quality. However,'it appears pertinent to note that alternative means of power production are accompanied by water, thermal, and air pollution problems.

Recreational use of New Melones Lake w ill slightly increase the amount of uncontrollable pollution. Increasing developments of various kinds and private recreational development upstream from or adjacent to the new lake may be expected, with associated basin waste increases subject to local control.

Disturbances to the soil due to construction of roads and other project facilities on the generally steep slopes of the reservoir w ill cause the area to have an Increased potential for erosion. This will contribute to turbidity and"sediment production in the reservoir,~as well as~adverse aesthetic impact , until vegetation is reestablished.

The Carson H ill mining area, located near Highway 49 in the project area containing about 30 acres of m ill tailing deposits, mine tunnel p o rta ls, and mine workings w ithin the h i l l would be inundated. The o re - bearing material in the mines has a low content of pyrite and heavy metals other than gold which are in quantities not economically feasible to mine. The tailings consists predominantly of sands and s ilt and contain very little of the ore-bearing materials from the mine. After initial f i l l i n g o f the re s e rv o ir, the ta ilin g s w i l l be submerged below wave action . A ll mines, tunnels and caves to be inundated that are determined to contain potential problems w ill be sealed. This w ill be detailed in the Hew Melones Lake Reservoir Clearing Design Memorandum.

Turbulence of the free flowing river and high mechanical reaeration in the area of the river inundated w ill be replaced by the less active and effective lake surface reaeration, thereby decreasing the waste assimi­ lative capacity. '------" ”

The impoundment of water would reduce the amount of sediment that is carried downstream. The reservoir w ill trap an estimated 19.000 acre- feet of sediment in 100 years of operation. This w ill amount to only 0.8 percent of the lake capacity. Nutrients conducive to biological growth stimulation w in also be trapped along with sediment in the lower strata of the lake.

Thermal stratification of the lake is expected based on observations of other lakes in the region and may result in anaerpMr rnnrUMrmt^jn the lower strata of the reservoir and in bottom sediments that could be responsible tor converting otherwise non-soluble materials into a soluble form.

These materials may Include iron, manganese, nutrients, and byproducts of organic decomposition that would impart undesirable color, taste and odor, which could possibly degrade the water supply for municipal use. This is of particular concern since withdrawals w ill be from this bottom strata. Uncontrolled basin development would greatly accelerate the rate of eutrophication in the lake compounding the discharge of undesir­ able materials and increasing the cost of treatment of water for municipal supply. Eutrophication is a natural process and up to a point can be beneficial to the lake fishery and not be detrimental for irrigation and recreation. With control of in*4>asin development, through adherence to water quality standards and objectives, concentrations of these materials in New Melones Lake are not expected to be sufficiently high to adversely affect the beneficial uses of the water, Including flow augmentation for purposes o f downstream water q u a lity .

b. Beneficial and detrimental aspects. - The magnitude by which the New Melones Lake project w ill reduce winter flows in the Stanislaus River is shown in tables 8 and 9. The existing average flows, ranging from 350 to 2,500 c.f.s., w ill have little effect on flushing action in the D elta and bays when compared w ith the Sacramento R iver flushing flow s, which average over 30,000 c.f.s. (47). It therefore appears that alter­ ation of the existing flushing flows w ill have a net beneficial effect on the downstream San Joaquin R iver and to some extent on the D elta and bays due primarily to flow augmentation being supplied when needed for water quality purposes as well as the increased summer flows.

The Public Health Service report (10) states that "High quality water released from New Melones Dam w ill be discharged to the San Joaquin River and w ill be instrumental in improving the quality of the San Joaquin River waters for all downstream beneficial uses. While the physical improve­ ment in quality parameters pertinent to each of these uses w ill not be very large and w ill not result in a satisfactory solution to the pollution problem in the lower San Joaquin River, the beneficial effects w ill be significant because of the widespread and intensive uses made of the river and the Sacramento-San Joaquin Delta. Water quality releases from New Melones project should be considered as a partial contribution to the overall solution of the pollution problem in the San Joaquin River rather than as a solution of the entire problem."

Much concern has been expressed over the effect of Increased irriga­ tion return flows which would result from the new irrigation water supply. In this regard it should be kept in mind that it is estimated that less than 15 percent of the new water supply w ill be used to irrigate additional land (see paragraph 4). The problem is therefore not as great as it would at first appear.

At the present time no treatment of irrigation return flows has been authorized other than the use of 70,000 acre-feet of water from New Melones Lake for water quality control purposes in the Stanislaus River and the San Joaquin River, and construction of a portion of the San Luis drain. Agricultural return flows from surface runoff would most likely contain a relatively low concentration of salt and are therefore not considered a serious water quality threat. Agricultural flows from underground tile systems would retain high concentrations of salts and are a serious threat to water quality. Waters from such systems are the waters that would be conveyed in drainage fa cilities which are under study (48).

The overall effect that the expected increase in irrigation w ill have is dependent on the effectiveness of action by the State Water Resources Control Board in setting and enforcing water rights and water quality stand­ ards for which they have responsibility by law.

The urgency of additional water supply for the Central Valley Project (CVP) has recently been brought into sharp focus by State Water Resources C ontrol Board D ecision 1379. The a d d ition a l D elta outflow which may be required to meet the water quality criteria outlined in that decision may- be of such magnitude as to utiliz e CVP water the U. S. Bureau-of-Reclamation had previously planned~for"firm water service to tHeUan Felipe and Folsom - South s e rv ic e areas o f the CVP.

Exact operating details and their specific impact on the environment w ill be defined by the U. S. Bureau of Reclamation within themext few years. Prior to initiation of operation,of the New Melones Lake project a supplementary environmental statement w ill be prepared and coordinated by the Bureau o f Reclamation.

Evaporation losses from the larger surface area of the new lake w ill increase from about 5,000 acre-feet occurring at the existing Melones Reservoir, to about 25,000 acre-feet annually at New Melones Reservoir. When these volumes are compared to the average Inflow to New Melones Lake of 1,130,000 acre-feet, the net annual increase in TDS w ill be a very small percentage of an already very low TDS concentration. The net storage effects, though expected to be very small, may decrease the summer flow TDS concentrations and increase, by a lesser amount, the winter TDS con­ centration, resulting in a desirable situation.

The Sonora-Keystone Unit reservoirs of the Central Valley Project Involving the development of water resources of the Stanislaus and Tuolumne River Basins would, if authorized and constructed, have a detrimental effect on water quality in New Melones (49). Increased development made possible by this prospective project would result in Increased municipal, industrial, agricultural and recreational waste loads being discharged into the South Fork Stanislaus River and thence to New Melones Lake. Inundation of up to 10,700 acres of land above gross pool of existing Melones Reservoir (containing vegetation, mines and their tailings), and sediments and nutrients from upstream would provide a source of potentially water degrading agents. During periods of stratification, anaerobic con­ ditions where they exist in the hypolimnion (lower strata) would be instru­ mental in converting otherwise Insoluble materials into a soluble form. The degree of water quality degradation cannot be accurately predicted at triis time. Observations of other reservoirs in the Central Valley indicate that during the late summer months water quality degradation would be at its highest point since reaeration of the hypolimnion would be minimal at this time. The water quality degradation would, in general, be limited to the hypolimnion in New Melones Lake and would have the most pronounced effect on Tulloch Reservoir due to direct releases into Tulloch/ Reservoir from the outlet in New Melones Lake that would withdraw water from below the thermocllne. Discharges from the outlet are not expected to contain living algae. Dead algae and end products of algae decomposi­ tion and other undesirable material may be expected. Considerable quan­ tities of organic matter and nutrients w ill be trapped along with sediments in the bottom of the lake.

Existing Tulloch and Melones Reservoirs have been subject to leachate, drainage and sedimentation from sites that would be Inundated by New Melones Reservoir and the water quality is described as excellent for all existing uses in Tulloch Reservoir (12). This indicates that the degree of water quality degradation that would be caused by inundation of these new materials w ill not be excessive and probably minimal. In-depth research contracted by the Corps of Engineers to investigate the effects of releases from various reservoirs upon fish populations and water quality, both within the reservoirs and tailwaters immediately below them, is currently underway (50). Results from these studies may be applied to the New Melones Lake project. Should the concentration of dissolved materials and dissolved oxygen be such that it would adversely affect the beneficial uses of Tulloch Reservoir (including the fishery), several methods could be adopted that would alleviate this situation even after the project is complete. These are discussed in subparagraph c of this section, "Remedial, protective, and m itlgatlve measures."

Downstream from Tulloch R eservoir, the water q u a lity w i l l be improved as a direct result of reaeration, for materials that entered the water under anaerobic conditions w ill be removed. The high degree of aeration that w ill occur as water spills over Goodwin Dam w ill produce downstream water quality that is comparable to the quality of the water that flows into New Melones Lake. Future developments in the basin could, unless properly controlled, adversely affect the water quality in the river basin, with or without the project.

c. Remedial, protective, and mitlgatlve measures. - Complete treat­ ment of agricultural waste water appears to be prohibitively costly at the present time. Studies are now in progress by the Bureau of Reclamation and the State of California to develop procedures for denitrification of return flows out of the San Joaquin Valley (48).

Use of the proposed San Joaquin Master Drain to receive the high dissolved solids load Instead of discharging them into the San Joaquin River would be beneficial (46). The Secretary of the Interior has stated that agreement by the State of California to its responsib ility for construction and operation of a drain system and its management to meet the water quality standards established under the Water Quality Act of 1965 is prerequisite to authorization of the East Side Division.

Adequate flows downstream from Hew Melones could help compensate for water quality degradation associated with return flows particularly in the interim period before new systems are developed such as the Peripheral Canal and upstream waste water treatment fa cilities by regional, State and Federal agencies.

M ulti-level outlets for Dew Melones Lake were considered. For anadromous fis h e r ie s enhancement, the o b je c tiv e is to obtain d esira b le low temperatures in the range of 42 to 60 degrees throughout the year. Evaluation of flows and temperatures anticipated from the single low level outlet indicates that this is a ll that is required to meet the temperature criteria (see paragraph 31a). Dissolved oxygen is another factor about which there is a concern. In the event that the releases of water with low dissolved oxygen from New Melones Intake have a detrimental effect on Tulloch Reservoir, hypollmnional aeration near the outlet structure in New Melones (52) or other aeration means at New Melones or in Tulloch Reservoir w ill be implemented. The aeration system would increase the dissolved oxygen concentration, thereby increasing, or reestablishing, the waste load assimilative capacity in Tulloch Reservoir and downstream. The aeration system would also stabilize the algal waste products and cause them to be removed to some extent by precipitation and trapping in the sediments of the lake and decrease the recycle rate of most materials. The effect of the low level outlet works on water quality parameters other than temperature and dissolved oxygen is uncertain and w ill be dependent upon the rate of eutrophication of the lake. Currently the watershed above the project is virtually undeveloped, and new development w ill be subject to California waste discharge requirements that w ill Include nutrient removal if necessary to protect the quality of the receiving waters. With a multi-level outlet, withdrawals from the epillmnlon or thermodine would probably be desirable for municipal purposes but would be of doubtful value to irrigation and would be detrimental to the downstream salmonold fishery by increasing the water temperature. It would also be detrimental to the lake fishery for it would reduce the most productive zone, containing high level of dissolved oxygen and also, by removing the better quality water would, in effect, increase the concentration of nutrients in the lake. A m ulti-level outlet with increased costs ranging from $5,000,000 for a two-level outlet to $5,800,000 for a three-level outlet, and with Inherent reductions in generating efficiency, is not justified for this project, on the basis of limited water quality needs such as municipal water supply.

Development within the project boundary w ill be controlled. In project recreation areas, measures to maintain water quality w ill include modern restrooms with sewage collection; portable chemical toilets wherever permanent restrooms cannot be provided; san itary dumping station s fo r travel trailers and boats; and garbage collection and sanitary landfill disposal. Consideration is being given to treating waste water from the Initial recreation facilities in evaporation waste ponds. Since this method of treatment produces no effluent, no surface water pollution w ill result. The ponds would be sealed with impervious material to pre­ vent or minimize any possible seepage to the groundwater. Nuisance con­ ditions including noxious odors are not expected. Waste water from future recreation development w ill either be treated on site with expanded fa c ili­ ties or exported to future regional facilities. Chemical toilets w ill be used exclusively at Mark Twain and Melones Recreation Areas and to some degree at Tuttletown and Glory Hole. These wastes w ill be hauled to an approved solid waste disposal site. Some pollution associated with recreational activities w ill be unavoidable, particularly that of oil, gasoline, and carbon monoxide resulting from boat operation. Outside of project recreation areas, little or no development or use is planned and no special water quality measures w ill be required.

Good quality water can be expected to flow into New Melones Lake since most of the Stanislaus River Basin above the project is within National Forest. It is the policy of the Forest Service to require that "National Forest land management practices are conducted in a manner which w ill ensure a quality water yield suitable for its intended purpose" and also that the "Forest Service w ill cooperate with the Department of Health, Education and Welfare and with States, counties and municipalities having jurisdiction over water for the purpose of ensuring safe supplies for domestic and recreation use and preventing and controlling water pollution from waste disposal." (See Forest Service letter dated 25 February 1972, in attachment C.)

Construction effects upon water quality w ill be minimal. Specific controls w ill be provided in the contract plans and specifications to control turbidity during construction. Such controls are formulated after coor­ dination with local, State, and Federal agencies responsible for the protection of water quality. Sedimentation and turbidity problems associated with this project are expected to be minimal since the materials to be handled are not prone to causing sediment and turbidity.

31. Effect on fisheries.

a. Conversions or changes. - Sixteen miles of free flowing river supporting a significant trout fishery w ill be inundated and converted into a lake fishery (3)(8). The existing warm water fishery in Melones Reservoir would be significantly increased and would be changed into a combination warm water and cold water fishery due to stratification of the lake. A cold water fishery may also be established in Tulloch Reservoir due to cold low level releases from New Melones Lake. Retention of substantial vegetation w ill provide ideal fish habitat while decayed vegetation w ill result in a minor contribution to eutrophication of the la k e .

For about four years after completion of a new reservoir the abundance of nutrients commonly cause a "boom" situation for the fishery in a lake. This is often followed by a declining fishery which eventually stabilizes at about one-half of the "boom" fishery.

Operation of New Melones would significantly alter downstream flows and temperatures. Changes in flows are discussed in paragraph 26, "Hydrology."

The following minimum releases w ill be made in accordance with the Bureau o f Sport F ish eries and W ild life schedule (3 ): TABLE 14 - MINIMUM FLOWS IN THE STANISLAUS RIVER FOR FISH

Flows Below Goodwin Dan Period Normal Year Dry Year

1 Jan-31 ilay 125 c . f . s . 100 c . f . s .

1 Jun-30 Sep 100 c . f . s . 50 c . f . s .

1 Oct-31 Dec 200 c . f . s . 150 c . f . s .

Annual Releases 98,000 acre-feet 69,000 acre-feet

A dry year is defined as one in which the natural inflow into Shasta, Trinity, Folsom, and Friant Reservoirs, as predicted for the water year, to ta ls le s s than 5,000,000 a c r e -fe e t, or one in which the combined water storage in Shasta, Trinity, Whlskeytown, Folsom, Auburn, and New Melones Reservoirs, as predicted for the water year, is less than 5,000,000 a c r e -fe e t.

In addition to changes in flows, changes in water temperature w ill directly affect the fishery.

A downstream temperature study was conducted by the Sacramento D istrict to determine whether New Melones Lake, as presently designed, would provide flows of the required quality to allow realization of a n ticip a ted fis h e ry m itig a tio n and enhancement (5 3 ). The study was based on the standardized method developed by the Corps of Engineers Hydrologic Engineering Center, Davis, California (54)(55). A 21-year period of record (1926-1946) was used for the study. The severest dry years in California history occurred during part of this period (1931- 1936). If and when such extreme drought conditions occur again, it is expected that widespread water shortages for all beneficial uses w ill occur throughout the region. The acceptable temperatures designated by the Bureau o f Sport F ish eries and W ild life (45) are 42° F. to 60° F. for 1 October to 31 March; 50° F. to 60° F. for 1 April to 31 May; 50° F. to 65° F. fo r 1 June to 30 September.

A summary of the results of this study are tabulated on the following page and in graphic form in chart IV. Under existing conditions it can be seen that for the months of August, September, and October tempera­ tures were almost never in the range specified as acceptable for fish. Under future conditions with the project, a drastic improvement is evident. In August, September, and October under future conditions, the downstream temperatures would be higher than the acceptable range only during years when the historical drought conditions would be expected to recur—this would be a rare occurrence. If it had not been for the rare dry years, 1931-1936, the project would be in the specified temper­ ature range at a ll times for the Important salmon spawning months of October, November and December. These dry year conditions have not recurred in the 36-year period from 1936 to 1971. In A p r il and May the downstream temperatures w ill occasionally, once in 21 years, be one degree or less lower than the range that was considered acceptable by the U. S. Bureau of Sport Fisheries and W ildlife. This slightly low temperature is not expected to have any significant adverse effects. TABLE 15 - PREDICTED TEMPERATURES FOR STANISLAUS “ RIVER DOWNSTREAM FROM GOOEWIN DAM (53)

Number of Times that a Particular Month is not in Specified Temperature Range (Based on historical flow records, 1921 to 1946)

Range L im it T o le ra n c e Jan Feb Mar Apr May Jun J u l Aug SeP Oct Nov Dec

A - EXISTING CONDITIONS

0° F. + 0 0 0 0 5 2 15 21 21 21 2 0 1 0 0 1 0 0 0 0 0 0 0 0 .5 * + 0 0 0 0 5 2 15 21 21 21 1 0 0 0 0 0 0 0 0 0 0 0 0 0 1* + 0 0 0 0 5 1 15 21 21 20 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2® + 0 0 0 0 2 0 13 21 21 19 0 0 0 0 0 0 0 0 0 0 0 0 0 0

B - FUTURE CONDITIONS: NEW MELONES WITH NEW DIVERSIONS^AND FISH AND WATER QUALITY RELEASES •

+ 2* 2* 6* 0 0

© 1 * * 0 0 0 0 0 0 0 0 0 2 1 0 0 0 0 0 0 0 .5* + 0 0 0 0 0 0 0 2* 2* 6* 0 0 0 0 0 1 1 0 0 0 0 0 0 0 1* + 0 0 0 0 0 0 0 2* 2* 6* 0 0 0 0 0 1 0 0 0 0 0 0 0 0 2® + 0 0 0 0 0 0 0 1 * 2* 5* 0 0 - 0 0 0 0 0 0 0 0 0 0 0 0

C - FUTURE CONDITIONS: NEW MELONES WITHOUT NEW DIVERSIONS— • +

o 2* 6* 0 0 • 0 0 0 0 0 0 0 2* 0 0 0 2 1 0 0 0 0 0 0 0 .5® + 0 0 0 0 0 0 0 1 * 2* 6* 0 0 — 0 0 0 1 1 0 0 0 0 0 0 0 1® + 0 0 0 0 0 0 0 1 * 2* 6* 0 0 — 0 0 0 1 0 0 0 0 0 0 0 0 2® + 0 0 0 0 0 0 0 1* 2* 5* 0 0 m m 0 0 0 0 0 0 0 0 0 0 0 0

1/ New Diversions means diversion of a ll new conservation yield from the Stanislaus River at or in the vicinity of Knights Ferry and is presented for comparative purposes only*

Occasions marked by asterisk occurred during the historical drought period of 1931-1936. b. Beneficial and detrimental aspects. - Loss of the river trout fishery in the reservoir area capable of sustaining up to 62,000 angler days annually by 2020 would be detrimental but would be compensated by establishment of a trout fishery in the reach of the river below Goodwin Dam capable of sustaining up to 70,000 angler days annually by 2020 result­ ing in a net increase in stream-type trout fishing of about 8,000 recrea­ tional days annually (3 )(8 ). New Helones Lake would also provide a cold water fishery, including trout and perhaps other species such as kokanee salmon. The new lake would sustain a far greater population of game fish than the existing lake and 16 mll€sn,<9f river combined, providing about 482,000 angler days annually of reservoir-type fishing (3).

The Improved downstream flow s, including the guaranteed minimum flo w s, w ill result in considerable fishery enhancement, particularly to the anadromous salmon and steelhead. E xistin g conditions fo r anadromous fis h along with a tabu lation o f estimated annual salmon runs fo r the years 1953 to 1971 are presented in paragraph 17. The improved flows and temperatures could also Increase the American shad and striped bass runs in the Stanislaus River and enhance the resident fishery. Since the flood period occurs in the Stanislaus R iver during the period in which the f a l l run king salmon spawn, reduction in peak floodflows and management of floodflows by means of controlled releases would have a beneficial effect on both adults m igrating upstream to spawn, the salmon eggs in the redds, and the emergent fry.

According to the California Department of Fish and Game (8) and the U. S. Bureau of Sport Fisheries and W ildlife (3), with the minimum flows agreed upon, the average annual f a l l run o f king salmon would be maintained at 11,000. Also, spring run king salmon, steelhead trout, and resident trout would be reestablished in the Stanislaus River due to improved flows and temperatures, p a rtic u la rly in the summer. Fishery enhancement b en efits credited to this project are attributed to an increase of about 8,000 salmon, due principally to the establishment of a new spring run of king salmon which w ill supplement the existing fa ll run, and to the establishment o f a run o f about 1,500 steelhead trou t annually. The Bureau o f Sport Fishe^ies'^utl^KWildlife has estimated that the increased fishery w ill pro­ vid e^ 819, OOO^Ln benefits annually creditable to the New Melones project (3 ).^Ocean-lmd inland sport fishing w ill Increase from 31,000 angler days annually without the project to about 93,400 angler days annually with the project. Ocean commercial harvest would Increase by 216,000 pounds of salmon annually. The steelhead and trout fishery that would be established would sustain 14,000 angler days annually (3). As can be seen in paragraph 26, "Effect on Hydrology," flows w ill usually be in excess of the minimum flow s and th erefo re ad d ition al enhancement beyond that predicated upon the minimum flows could be expected. If a ll the new conservation yield is not d iv e rte d , a d d itio n a l enhancement to the fis h e r ie s w i l l be re a liz e d . Improved water quality conditions as discussed in paragraph 30 w ill also be instrumental in improving the fisheries. No estimate of these potential fishery increases and resultant benefits is presently available.

Factors which could occur to offset the degree of enhancement discussed above would be mining nf rlYPy PTfl^f1 and water diversions both in the Stanislaus River and San Joaquin River, particularly during the downstream migration of eggs (American shad, striped bass) and recently hatched fish (salmon, steelhead). In some instances reregulated flows have been shown to adversely a ffe c t spawning h ab itat due to rip arian and aquatic weed encroachment. Reregulated flows in the Stanislaus River would result in considerably higher summer flows with colder temperatures and thereby preclude the present degree of plant and aquatic weed encroachment. Rirther reduction of riparian encroachment would be accomplished when required as a part of the downstream channel maintenance project for flood control and other purposes. Downstream maintenance w ill be multi-purpose for the purposes of flood control, spawning gravel preservation, w ildlife and recreation.

Reduction in floodflows could possibly adversely affect spawning gravel by eliminating the scouring and flushing action necessary to remove sediments and retain suitable spawning conditions in the reach above Oak­ dale. In the downstream portion of the Stanislaus River, the channel capacity is presently 8,000 c.f.s. Flows in excess of 8,000 c.f.s. over­ top the banks and levees and do not substantially aid in flushing or scouring of gravels. The reregulated flows w ill have sustained, rather than peak, scouring flows and this change is not expected to appreciably diminish the usefulness o f the spawning g ra v e ls .

Another common effect of dams is that they prevent gravel from moving downstream to rep len ish the spawning gra vel that is removed during high flows. Since existing Goodwin, Tulloch and Melones Reservoirs presently prevent the replenishment of spawning gravel to the downstream reach, New Melones is not expected to have a significant adverse effect in this resp ect.

c. Remedial, protective, and mitlgative measures. - Protective measures incorporated into the project include establishment of a fish management area in the lake, guaranteed minimum fishery release flows, and water quality release flows to provide water that is suitably high in dissolved oxygen (and low in total dissolved solids) for improved fishery conditions.

A plan is being developed for protecting and enhancing fish and wild­ life habitat along the Stanislaus River below New Melones Lake. Based upon the recommendations of the State and Federal fish and w ildlife agencies, a range of alternative proposals has been developed (paragraph 9). When a plan is selected from this range and implemented, by the Corps of Engi­ neers as authorized, it w ill provide mitigation for the loss of riparian resources and w ildlife habitat inundated by the reservoir, preserve stream- bed g ra vels fo r the fis h e ry enhancement b en efits associated with the p ro je c t, assist in mitigating the loss of the trout fishery in the reservoir area, provide for increased public use and access along the river, and provide an integrated plan for use by the Corps of Engineers in discharging its responsibilities to maintain the flood carrying capacity of the Stanislaus River to 8,000 c.f.s. The alternative plans are being coordinated with a ll interested agencies, and are being discussed with the fish and w ildlife agencies to insure that their recommendations and responsibilities are fully considered. The alternatives have been presented to the general public in a pu blic meeting held in Modesto, C a lifo rn ia , on 2 March 1972. Views expressed and information obtained are being evaluated to insure that local views are fully represented. When the views of a ll concerned have been obtained and fu lly evaluated, a plan which w ill best meet the objectives and requirements of the project and respond to the desires of all concerned as fully as possible w ill be tentatively selected. An additional public meeting w ill be held to present the tentative plan and additional views and information thus attained w ill be considered in recom­ mending the plan to higher au th ority fo r implementation.

32. Effect on land use.

a. Changes or conversions. - About 25,059 acres o f land w i l l be required for the project, 12,500 acres of which w ill be inundated when the reservoir is at the gross pool level. About 1,800 acres of this area are already inundated by the existing reservoir at its gross pool. The new reservoir w ill inundate about 10,700 additional acres of land currently used for domestic stock grazing and w ildlife. Lands to be acquired for the project include about 3,614 acres of Oakdale and South San Joaquin Irrigation District lands, of which about 1,228 acres are below gross pool elevation (735 foot contour) of the existing reservoir; about 5,301 acres of public lands administered by the Bureau of Land Management property; and about 16,144 acres of privately owned lands.

Of the privately owned lands, about half are currently used for grazing and about half remains undeveloped and is good w ildlife habitat at present. Some of the w ildlife supported by this habitat would be per­ manently lost, while some would be replaced by the mitigation measures discussed under paragraph 33. About 2,520 acres o f land around Peoria Mountain w ill be managed for increasing the w ildlife carrying capacity of the area. Another 2,293 acres of land around Bostick Mountain and other lands around the perimeter of the reservoir not designated for special use w ill also be used by w ildlife. About 2,900 acres are designated for intensive recreational use and development and about 2,300 acres w ill be available for public access. About 16 miles of fish habitat and riparian w ildlife habitat would be inundated. Portions of Highway 49 and Parrott's Ferry Road w ill be relocated and new and much larger bridges constructed. Existing overhead u tility lines affected by the larger reservoir w ill be relocated.

Land use downstream could be altered at an accelerated rate due to . flood control and irrigation benefits of the project. Continuous agri­ cultural enchroachment is the greatest single threat at the present time to riparian lands. With the project, additional secondary development such as residential and recreational homes, boat docks, concession stands, irrigation diversion structures, and canals could occur.

Downstream land may be acquired for w ild life mitigation and for providing an 8,000 c.f.s. floodway. If acquired in fee this land would be taken off the tax rolls. However, under 33USC 701c-3 (56) local county agencies receive 75 percent of a ll monies that are deposited in the U. S. Treasury on account of out-leasing of lands acquired by the United States for flood control, navigation and allied purposes.

Land use patterns may also change in areas that may receive irrigation waters. In some areas farmers w ill find it more economical to use the new irrigation water rather than ground water, and same irrigated lands that are presently receiving water of poor or marginal quality would use the better water to irrigate their lands. Therefore there would not neces- sairly be a significant net gain in irrigated acreage.

b. Beneficial and detrimental aspects. - There would be a net reduction of wildlife habitat due to: inundation by the reservoir; ' conversion of w ildlife habitat to agricultural use as a result of new irrigation yield from the project; and secondary development in the areas downstream from Goodwin Dam that w i l l be protected from flood s and around the new lake. The Peoria Mountain w ildlife mitigation lands acquired at the reservoir and any additional lands acquired for this purpose along the Stanislaus R iver downstream from Goodwin Dam are expected to o ffs e t the reduction in accordance with the recommendations of the fish and wild­ life agencies (57)(58). Beneficial effects w ill result from establishment of these w ildlife management areas, thereby preserving them from future development.

Accelerated secondary development, particularly agricultural activities, could take their to ll of the rapidly diminishing riparian lands. Develop­ ment of extensive recreational facilities at the reservoir would benefit large numbers of people throughout the area. As discussed in paragraph 24, recreation-oriented activities w ill be stimulated by the project. Outside the project area the greatest impact w ill be along highways where zoning ordinances permit commercial development, and in the nearby towns o f Sonora, Jamestown, Columbia, and Angels Camp. The business d is t r ic t s o f these towns cu rren tly have poor u t iliz a t io n of land containing unused structures, undeveloped lots, and inefficiently used buildings. Because of building codes and zoning ordinances existing in both counties (36)(37)(60), and influx of money from tourists, this land w ill be upgraded and w ill absorb much of the future business growth. No environmental harm w ill result from this shift. Where additional space for business and urban expansion occurs, environmental harm could result. Development along main thoroughfares would cause only limited environmental harm since the roads and other development have already replaced most of the natural values. About 3Z.000 acres of land have already been purchased primarily for speculative "ranch style" development near New Melones Lake (see paragraph Additional large scale subdivision is not anticipated in the forseeable future. Second home recreation development could result in an adverse impact on the environment if not properly controlled. Such controls exist and are discussed in part c of this paragraph.

Though the beneficial economic impact on the lands and towns close to the project w ill be considerable due to increased land value and demand fo r goods and s e rv ic e s , the low summer and high w in ter unemployment pattern can be expected to persist because of the seasonal nature of recreation-oriented businesses.

Local law enforcement efforts w ill need to be increased to keep pace with increased public use at the project. Other services and resulting costs to the counties w ill also increase.

New irrigation water w ill allow some new land to be developed for agriculture and permit existing agricultural land to remain in use by reducing the present overdraft on ground water.

The relocations of a portion of State Highway 49 and the Parrott's Ferry Road, including new bridges at each reservoir crossing, w ill replace existing portions of these highways which w ill be inundated. These relo­ cations w ill also eliminate about 5 miles of steep, winding roads.

c. Remedial, protective, and mltigative measures. - Measures to mitigate for lost w ildlife land are presented in paragraphs 9 and 33 and include plans for protection of downstream riparian land. Paragraph 10 presents plans with which the natural resources adjacent to the lower Stanislaus R iver can be preserved. Methods o f p rotectin g the environment from construction activities are presented in paragraph (34). Measures for mitigating cut and f ill areas for the Highway 49 relo­ cation include erosion-control slope seeding by the California Division of Highways. For the Parrott's Ferry Bridge relocation, plans w ill require excess spoil to be wasted in designated areas below inactive pool. Road cuts and fills and all construction activities w ill be conducted to minimize scarring of the terrain along the new alignments.

Existing overhead high-voltage powerlines and telephone lines w ill also be relocated. Current plans for relocations w ill consider all oppor­ tunities for relocating or consolidating lines or otherwise minimizing the visual impact of overhead lines. Abandoned facilities w ill be removed by the u tilitie s companies who own them.

In accordance with the Uniform Relocation Assistance Act, Public Law 91-646, the Corps of Engineers w ill assist the .30 or so people that w ill be displaced by the project to relocate, and the law provides for paynififlt Of actual^ reasonable moving expenses. Detailed planning, design, construction, operation, and maintenance w ill be conducted to insure that the presence of large numbers of people at the recreational areas w ill not create serious problems of traffic, boating safety, law enforcement, overuse of resources, and others. The Corps of Engineers and the Bureau of Reclamation are maintaining coordination with local government as the project proceeds so that local planning may prepare for increased respon­ sib ilities for law enforcement and other activities when the project is completed and placed in operation.

The only practical method of avoiding any adverse effects of possible secondary development outside of the new flood lim its, which w ill be stimulated by improved flood control, is prudent local planning and zoning.

Although land acquisition for New Melones Lake has been predicated upon established Federal policy (61), the Corps of Engineers w ill study the p o ssib le need and ju s t ific a t io n fo r recommending an exception fo r acquisition of additional lands that might be needed for further compre­ hensive protection of environmental resources adjacent to the lake.

Calaveras and Tuolumne county planners are interested in preventing the environmentally destructive "speculative subdivisions." Both counties have subdivision laws that prevent the worst of these abusive subdivisions (36)(37)(60)(62). Some of the areas of greatest concern to the counties are:

Drainage - Both counties require detailed drainage and contour studies, as well as the calculations used to design drainage structures. Roads - Calaveras and Tuolumne Counties recquire construction materials and design standards to meet county criteria. Additionally, bonds for the estimated value of the road work to be done must be posted (this Is to insure completion of the roads).

Water - Ties to existing water lines are encouraged. If wells are used, they are carefully inspected to assure that they comply with minimum quantity and quality.

Sewage - G eological studies are required fo r drainage i f s ep tic tanks are used. Calaveras County requires that subdivisions with lots of 2 acres or less must set up reserve funds for future sewage treatment systems.

Fire - Both counties require fire protection either using water from water systems or from reserve standing pools.

The subdivision regulations of both counties discourage poorly developed subdivisions and require that basic environmental hazards be m itiga ted .

If future development follows sound guidelines such as general plans and associated planning tools prepared by the counties and cities and if these plans Include special provisions for such important matters as adequate effluent discharge, guidelines set by the California Regional Water Quality Control Board, environmental degradation w ill be kept at a minimum.

The Stanislaus River Designated Floodway when adopted by the Recla­ mation Board w ill control development within the floodway. The Corps of Engineers and the Reclamation Board encourages local governments to adopt necessary regulations to preserve environmental quality.

33. Effect on W ildlife.

a. Changes or conversions. - New Melones Lake w ill inundate approx­ imately 10,700 acres of w ildlife habitat at gross pool. The land to be inundated supports a cross section of the various plant communities found at this elevation. Total w ildlife numbers w ill be reduced but generally species variety w ill remain unchanged. The area to be inundated includes 57 miles of perennial and intermittent streams supporting about 1,000 acres of riparian habitat. Riparian dependent species such as the water ouzel and the northern water shrew w ill be obliterated along with the riparian habitat in the upstream project area. Additionally, the 1,500 acres of lands proposed for basic recreational fa cilities and access and the 2,675 acres required for future expansion of recreational facilities w ill further reduce the w ildlife habitat and population through increased public use, development, and increased stress upon the various w ildlife species. On lands affected by the fluctuating water level of New Melones Lake, vegetative growth of early maturing annuals would be discouraged by the fluctuating water level and growth of plants such as the turkey mullein, cocklebur, and succulent herbs that would provide limited food and cover for w ildlife would be encouraged. The ground cover around the existing Melones Reservoir has vegetative cover similar to this and currently sustains a large number of doves, quail, and rabbits during summer and f a l l months (8 ).

Flood protection would stimulate downstream_land-development. At the present time, w ildlife inhabiting- the riparian land along the Stanislaus River below Knight's Ferry are threatened by the continuous agricultural expansion to the river's edge. From 1958 to 1964, agricultural growth eliminated 752 acres of riparian land. The remaining 995 acres suitable for crop production w ill probably be developed within 20 years (8). With the project's additional flood control, losses to riparian habitat w ill be accelerated unless remedial or protective measures are taken.

In the upstream reach of the project area riparian habitat w ill be obliterated while very little canyon slope vegetation w ill be lost since this portion is relatively narrow.

b. Beneficial and detrimental aspects. - W ildlife habitat w ill be lost due to inundation. The construction of recreation facilities, roads, borrow pits, dam, spillway, and other facilities w ill further reduce the w ildlife habitat. Intensive recreational use seasonally reduces the availability and desirability of wildlife habitat. Since wildlife displaced from their habitat could only move to nearby habitat already occupied by other w ildlife, w ildlife from adversely affected habitat w ill be lost to future use unless some means of w ildlife habitat replacement can be found.

Flood p rotection o f downstream lands w i l l re s u lt in a d d ition al loss of w ildlife habitat due to agricultural, urban, and recreational expansion unless protective or mitlgative measures are taken. The floodway plan previously discussed w ill, when adopted, substantially protect the down­ stream habitat. The increased summer flows would prevent the present degree of encroachment by riparian vegetation on the streambed gravels of the lower Stanislaus River.

The Increased reservoir shoreline at New Melones Lake w ill provide an "edge effect" which w ill result in Increased food supply for some species of w ildlife. Waterfowl use with the project w ill increase slightly with the enlarged reservoir, particularly during the winter months, although the expected increased human utilization associated with water based recreation w ill discourage waterfowl use during summer months (8 ). c. Remedial, protective, and m itlgative measures. - Vegetative cover removal w ill be minimized. Areas above gross pool where vegetation has been removed as part of construction activities w ill be seeded with suitable species of plants. To mitigate for w ildlife losses associated with Inundation of habitat, 2,520 acres of land east of the dam w ill be purchased. It w ill be operated In accordance with a General Plan developed cooperatively between the California Department of Fish and Game, the Bureau o f Sport Fish eries and W ild life , the Bureau o f Reclamation, and the Corps o f Engineers. The m itig a tio n area is known as the Peoria Mountain W ildlife Management area. The following tabulation shows the type of habitat in this area.

TABLE 16 - PEORIA MOUNTAIN WILDLIFE MANAGEMENT AREA - COVER TYPE

Percent Cover Type o f T o ta l

Grass 6 Woodland-Grass 33 Woodland-Chaparral-Grass 37 Chapa rral-G ras s 5 Chaparral 17 Cultivated-Urban-Barren 2 TOTAL 100

In addition to the lands to be acquired specifically for w ildlife mitiga­ tion, an additional 2,293 acres of additional project lands in the vicinity of the dam and spillway w ill be available for w ildlife use after construc­ tion. To some extent w ildlife populations can be increased through habitat manipulation, and losses to w ildlife substantially mitigated, by increasing the w ildlife carrying capacity on the w ildlife area.

A number of w ildlife cultural practices are available to be employed as mitigating measures. Fencing of the w ildlife area and other lands w ill permit w ildlife to increase on acreages where there are presently conflicting uses of the available forage. Chaparral, particularly old stands, can best be managed for w ild life through a combination of crushing, discing, burning, and chemically treating small areas. This provides considerable edge or heavy brush cover adjoining management areas, providing a good food supply for w ildlife.

Downstream riparian land w ill be protected from accelerated agricul­ tural and other development to prevent losses of w ildlife habitat due to the project. Without Mew Melones project some of these riparian habitat areas would be converted to other uses. The protection the project w ill afford these areas can therefore also be considered mitigation for the loss of riparian habitat in the reservoir area. Flans for preserving downstream rip a ria n v eg eta tio n are presented in paragraph 9.

34. Effect of project construction activities.

a. Changes or conversions. - Activities to date are included in section 1, paragraph 1.

This work has resulted in a construction expenditure to date of about $20 million and has employed about 75 people at the site who reside in or near the p ro je c t area. I t has also resu lted in increased employment in areas close to the project.

Future work w ill include completing construction of the diversion and outlet works tunnel and construction of the dam and spillway, road and u tility relocations, powerhouse, surge tank, reservoir clearing, and remaining access roads and in itial recreation facilities. This construction w ill cost roughly an additional $160 m illion and employ approximately an additional 150 people who w ill reside in or near the project area during the construction period and w i l l a lso increase employment in nearby com­ m unities.

Major construction items to be initiated in calendar year 1972 are the relocation of Highway 49 and the construction of the dam and spillway. About 16,000,000 cubic yards of material w ill be required for construction of the dam. This w ill be obtained by excavating about 13,000,000 cubic yards from the spillway, about 2,000,000 cubic yards from a borrow area adjacent to the s p illw a y , about 800,000 cubic yards from the l e f t abutment and about 200,000 cubic yards from another borrow area. The future relo­ cation of Parrott's Ferry Road w ill also involve moving earth. Reservoir clearing operations w ill involve removing vegetation and debris. ' Trees and other vegetation w ill be removed in specific areas of the reservoir to avoid hazards to boating and swimming.

b. Beneficial and detrimental aspects. - The influx of construction workers for the project is expected to result in temporarily increased retail sales, services, construction, and other business. These activities w ill provide additional tax revenues, as well as increased cost of county services that often are a burden on local schools. Since this anticipated increase in development w ill be relatively rapid, planning and related actions w ill be needed by the two mountain counties.

Construction activity would increase the risk of fires with subsequent increases in the sediment load that would be introduced into the river during runoff. Borrow material for the rockflll dam Including material excavated from the spillway w ill result in limited scarring of the terrain in the area northwest of the dam. Project associated recreation facilities con­ struction w ill require moving large amounts of earth for the construction of access and circulation roads, and parking areas and oxidation ponds for sewage disposal. These facilities w ill be planned to minimize adverse environmental impact, but seme scarring of the terrain is unavoidable. During construction, the exposed borrow areas would be a source of silta- tion at times of rainfall; such siltation w ill be controlled by construc­ tion procedures and w ill not seriously affect aquatic life in the river and in Tulloch Lake. Vegetation that is retained in the lake for fish habitat w ill also affect the water quality in the lake by contributing nutrient enrichment. Due to the slow rate of decay of woody material and the large volume of water involved, this effect is expected to be relatively small and more than offset by benefits expected from its con­ tribution as fish habitat. Additional discussion of the effects of con­ struction activities on water quality can be found in paragraph 30.

c . Remedial, protective, and mltigative measures. - The project- associated facilities (temporary administration building, contractor's work area, new powerhouse, power switchyard, surge tank, contractor's haul roads, access to top of dam, etc.) w ill not be within view of recre­ a tio n is ts on the lake or at the public use areas except the downstream overlook. The construction of recreation facilities and appurtenant roads and parking areas w ill be constructed to minimize environmental disturbance and a ll cuts and fills w ill be revegetated to harmonize with the existing vegetation. Because of the extensiveness of the development, however, some environmental damage is unavoidable.

Borrow areas for the main dam including the spillway w ill be located north of the high ground on the north side of the river out of view from the downstream pu blic overlook. Excavation has been c a r e fu lly planned to retain a number of "islands" of undisturbed soil and native growth of about one acre in size in the borrow areas which are expected to ame­ liorate the appearance of the surrounding disturbed areas and help reseed the excavated areas. Also, after completing excavation, slopes w ill gen­ erally be restored to blend in with the natural topography and topsoil w ill be replaced and reseeded to facilitate natural revegetation and to curtail erosion.

A ll reasonable attempts w ill be made to avoid fires during construc­ tion. Fire suppression equipment and personnel w ill be at the project area during construction. The overall plan for fire protection during construction has been established in accord with the desires of the State Division of Forestry.

Plans and specifications for the main dam contract w ill include environmental protection requirements that w ill be an integral part of project construction (63). Under Public Law 81-874 r e H p f -tg authorize d from the U. S. Commissioner o f _Fdi,oaMnn frr th? lo c al school districts when the influx of consEfuctionworkers and their families is a burden on the school facilities in the area.

35. Visual effect of project.

a. Changes or conversions. - New Melones Dam w ill be constructed in a r e la t iv e ly narrow canyon about 3/4 m ile downstream from the e x is tin g Melones Dam, and w ill consist of about 16,000,000 cubic yards of rock and earthfill, rising 625 feet from the riverbed. The material for the dam w ill be obtained from excavation of the spillway and borrow areas adjacent to the spillway. The powerhouse, switchyard, and surge tank w ill be located on the north abutment opposite the dam and opposite the downstream over­ look. The surface area of the new lake w ill be seven times larger than the existing lake.

Gross pool is at elevation 1,088 feet, but vegetation is expected to survive and w ill be retained above the selected "clearing line," elevation 1,068 feet. In "average" years toward the end of the recre­ ation season, there w ill be a visible gap of about 50 vertical teet trotg— clearing line to the~W5ter surface exposing a total of about 1.900 acres.* At times of lowered pool levels'^ .tire uxpusud teservolr 'slopes below clear- ing line w ill present an appearance of rocky and sandy slopes, with hori­ zon tal bands caused by wave action where the water le v e l has remained stationary for short periods. The sandy areas w ill serve as informal beaches. The average drawdown during the summer recreation season (period of heaviest use between Memorial Day and Labor Day weekends) in any one year w ill be about 40 feet, or about 5 inches per day. The water level at any given time w ill depend not only on whether it is early or late in the season but also on whether the season is in a "wet" or "dry" series of years. In "wet series" years, early in the season, there w ill be almost no v is ib le drawdown. In "dry s e rie s " years, the low est le v e l reached w i l l be about 218 feet below clearing line (elevation 1,068 feet) in summer and about J?50 ™ c le a rin g line in October or November. About 8,400 acres would be exposed at a drawdown of 260 feet. This would occur less than once in 25 years on the average. Operation studies show that the water level in Tulloch Reservoir w ill be higher with New Melones Lake in operation, on the average, than the average level which currently exists. Power releases from the New Melones powerplant could cause fluctuations of up to 10 feet during a weetciy cycle in Tulloch Reservoir, but tne net "effect would depend p a rtly on the ir r ig a tio n operation~of~the re s e rv o ir. The irrigation districts attempt to lim it fluctuation as much as possible during the recreation season.

* Because of numerous canyons and the vast size of the lake only a fraction of the drawdown zone w ill be visible from any vantage point. b. Beneficial and detrimental aspects. - New Melones Lake, about seven times larger in surface area than existing Melones Reservoir with arms reaching back up deep canyons w ill, when fu ll or nearly fu ll, sub­ stantially increase the scenic value of the area. New roads and bridges w ill provide excellent views of the reservoir and surrounding terrain. Project lands, which might otherwise have eventually been converted to other uses, w ill be preserved as public resources for extensive informal use as well as more Intensive use at the developed recreation areas. The w ild life mitigation areas and undeveloped extensive land and water areas w ill be maintained for their scenic value as well as for other specific project needs.

The reservoir w ill be operated in such a manner that there w ill be a fluctuating shoreline. The average amount of drawdown in any one recreation season would be about 40 feet. Since the pool w ill usually be fillin g to its maximum level about 1 July, and most releases for irriga­ tion w ill be completed by about 1 October, the average dally drawdown during this period w ill be about 5 inches. Shoreline erosion due to steep­ ness of slopes and waves from wind and operation of power boats is expected to occur and w ill contribute to the unattractiveness of the drawdown zone between gross pool and recreational pool.

The massive dam, the spillway, and the powerhouse, switchyard, surge tank and the recreation developments w ill become prominent features of the landscape, but it is difficu lt to assess their aesthetic values since they w ill be pleasing to some people and less pleasing to others. This is because aesthetics is a subjective matter varying from individual to individual and even varying for the same individual at different times. Also, it is a subject that is strikingly influenced by prevailing cultural a ttitu d e s .

c. Remedial, protective, and m itigative measures. - The main dam, surge tank, and powerhouse w ill be designed with special architectural treatment to harmonize them with the canyon in which they are to be located. Structures at recreational areas w ill be designed to harmonize with the surroundings. Mr. Paul Thiery, a noted architect, has been retained by the Corps o f Engineers as a consultant to recommend s p e c ific design features for this purpose. The design recommendations w ill be generally in conformance with the overall theme of the "49er era" (remindful of the time about 1849 in California's history) as described in the master plan now under preparation. After completion of a ll construction, restoration of the work site w ill be accomplished as discussed in paragraph 34.

Vegetation w ill become established in the reservoir drawdown area on a volunteer basis and from specific plantings aimed at reducing the u n a ttra ctive appearance o f bare wavewashed slopes. Observations at recently have Indicated that volunteer Bermuda grass and other species present an attractive appearance over much of the exposed reservoir area. Recent research results from a five year effort by the University of Calif­ ornia at Davis for the Corps of Engineers and other agencies Indicates that there are additional species of vegetation which can be utilized which w ill survive the harsh environment of alternately flooded and dry reservoir slopes (59). This Information and additional experimental vege­ ta tiv e planting work now underway by the Corps o f Engineers a t nearby New Hogan Lake w ill assist in the development of a suitable vegetative plan for New Melones Lake (64). The feasibility of reducing the extent of blacktopped parking areas by provided paved areas large enough to accomodate normal weekday use, with additional areas needed to handle weekend and holiday use to be turfed with hardy, low-maintenance grass, is being investigated. SECTION IV - ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT BE AVOIDED

36. Whitewater boating loss. - Between Camp Nine and Parrott's Ferry Bridge, (about 9 miles) whitewater boating w ill not be commercially feasible after fillin g of the reservoir and w ill be possible only for limited distances in a "dry series" of years, after fillin g of the reser­ voir. In the Parrott's Ferry to Highway 49 reach, (about 5 miles) this activity w ill not be possible after a period of perhaps 8 to 9 years after project completion. Commercial boat operators and some members of the Sierra Club object to the loss of this resource.

37. Historic, archeological, and geological loss. - The foundations of the Melones gold smelter, Robinson's Tavern, and the sites of Robinson's, Parrott's, and Abbott's Ferries w ill be inundated. Most archeological sites, together with any artifacts not removed, including the Indian petroglyphs located on the c l i f f about 3/4 o f a m ile upstream from Highway 49 bridge, w ill be inundated. There are 10 caves located below gross pool elevation which w ill be inundated.

38. Scenic value losses. - The excavated borrow areas and a variety of project-associated features including the recreation areas w ill result - in some unavoidable scarring and loss of natural vegetation and scenic terrain features. During annual reservoir drawdown, belts of non-vegetated land between the upper and lower pool limits w ill be exposed. Many people consider this to be unattractive. Such zones are typical at all multiple-purpose and irrigation reservoirs in this region.

39. Water quality reduction. - Secondary development both around the reservoir and downstream, which would be stimulated by the project, would increase the residual waste entering the reservoir and the river. The State Water Resources Control Board and local authorities could reduce the degree of net water quality degradation. To the extent that the con­ servation yield from New Melones Lake project is used for increased agri­ cultural use, irrigation return flows, unless properly treated or controlled, would also result in water quality degradation. Uncertainties concerning use of the conservation yield at the present time (paragraphs 4, 30, and 51) preclude extensive treatment of this subject. This w ill be discussed in the environmental impact statement that w ill be prepared by the U. S. Bureau o f Reclamation fo r the p ro je c t operation.

40. W ildlife and w ildlife habitat losses. - W ildlife habitat within the project area would be eliminated. This includes 10,700 acres of land that would be Inundated above gross pool of the existing reservoir and the 2,900 acres that w ill receive Intensive recreational use. This loss of w ildlife habitat would be substantially mitigated for by improving wild­ life habitat on w ild life management areas and on adjacent lands acquired for the project and by protecting w ildlife habitat in the downstream area as discussed in paragraphs 9 and 33c. SECTION V - ALTERNATIVES

41. Alternative reservoir sites. - Following the determination that res­ ervoir storage was the only practicable means of developing the resources of the Stanislaus River and to provide protection and safety to the communities in the river basin, studies were made of various dam sites on the river and the storage capacities that could be provided. One appraisal showed that increasing the size of the existing Tulloch Dam, to produce comparable benefits, would be considerably less economical than a project at the New Melones site. A larger Tulloch Reservoir would require a dam with a crest length of about one mile long. The existing topography on the r ig h t abutment is such that ad d ition al dikes would be required to contain a 2,480,000 a c re -fo o t re s e rv o ir. Construction o f a downstream dam and afterbay for reregulation of power releases would also be necessary. It is estimated that a new dam at Tulloch having a reservoir of about 2,480,000 acre-feet capacity would inundate about seven miles less of Stanislaus River than would New Melones Lake. This would not Inundate the best reach for whitewater boating. With this reservoir, essentially the same historical sites would be inundated as with the authorized project. The caves would be affected to a lesser degree than with a 1,100,000 acre- foot reservoir at the New Melones site. The cost of such a project would be about $270,000,000, which is about $90,000,000 more than the authorized New Melones project.

An enlarged Tulloch Reservoir having a capacity of about 1.000,000 acre-feet could be'op'erated to provide about the same flo"od"control, water quality and downstream fishery benefits as the authorized New Melones Lake project. Such a reservoir is estimated to cost about $130.000.000. It would result in the loss of both the existing Melones and Tulloch power- plants and would forego the development of the hydroelectric and water conservation potential of the river at this location. A new 1,000,000 acre-foot reservoir at Tulloch would not result in any loss of the white- water boating area. Such a project,^however, is estimated to have a benefit-cost ratio of less than'0.5 to 1 and would not be economically ju s t ifie d .

An enlarged Tulloch Dam to provide 630,000 acre-feet of storage would not inundate the whitewatef reach of the Stanislaus River. Such a reservoir would provide flood control comparable to the authorized New Melones project but would not Include storage for additional water conser­ v a tio n , water q u a lity , fis h e ry enhancement or power. The e x is tin g power­ house below Melones Dam would be inundated and the present powerplant at Tulloch Reservoir would also be rendered inoperable. This would result in considerable loss of power revenues and a diminished supply of electrical energy. There would be no storage to provide water needed for fish releases, nor would storage be available for water quality. A 630,000 acre-foot reservoir at the Tulloch site would cost an estimated $88,000,000 and, due principally to not developing the power and irrigation yield that is possible with a larger reservoir, cannot be justified economically (BC ratio about .5 to 1).

Sites upstream from the existing Melones Dam would not provide the required degree o f flo o d p rotection to downstream areas because much le s s of the basin drainage would be controlled to reduce floodflows. There is no upstream dam site above the Whitewater reach that would include both the~Nortn and South Forks o f the Stanislaus R iver; th erefo re, more than one dam would be required to control runoff for flood control. Limited storage at the upstream dam sites would preclude adding storage for other purposes such as water conservation, power generation, water q u a lity and fish releases.

42. Alternative reservoir sizes at the New Melones site. - Various alter­ native reservoir sizes were considered at the New Melones site with the objective of obtaining the maximum net benefits from development of the site. The optimum size reservoir was determined to have a 2,400,000 acre- foot capacity. Three other possible reservoir sizes are discussed below to illustrate the relationship of capacity to benefits and the corresponding environmental impacts.

a. A flood control reservoir with in itial gross capacity of 450,000 acre-feet, with provisions for enlargement to 1,100,000 acre-feet for con­ servation purposes, was the project authorized for construction by the Flood Control Act of 1944. Gross pool elevation for 450,000 acre-foot storage would be about elevation 850 feet, just above the presently author­ ized project's inactive pool. The environmental impact of the 450,000 acre-foot plan would be essentially the same as the existing Melones Reser­ voir, since much of Melones is surrounded by steep-sided h ills and there is virtually no adjacent development. However, the remains of the gold smelter and Robinson's Tavern at Melones, and most of the archeological sites would be inundated. At elevation 850 feet, the 450,000 acre-foot reservoir would eliminate the existing whitewater use between Parrott's Ferry Bridge and Highway 49 bridge and would create about one and one h a lf mile of fla t water in the reach between Camp Nine and Parrott's Ferry. Both Highway 49 and Parrott's Ferry Bridges would have to be relocated.

b. Subsequent studies indicated this 450,000 acre-foot plan would be an undesirable and in e ffic ie n t committment o f a valu able dam s it e , because it would not include any storage for additional water conservation, water q u a lity , fis h enhancement or power. Studies by the Corps o f Engi­ neers, the Bureau of Reclamation, and the State of California resulted at one time in a recommendation for construction of a 1,100,000 acre-foot re s e rv o ir and a new powerplant. A "Report on Economic F e a s ib ilit y " was prepared in 1957 and Indicated such a project was economically justified for flood control, irrigation, and power. This would include the same flood protection as the authorized project, 175,000 acre-feet average annual yield for water conservation and a 84,000 kilowatt powerplant. The environmental impact of this 1,100,000 acre-foot reservoir would be similar to that of the presently authorized project. A 1,100,000 acre- foot reservoir would have a surface area of 8,050 acres at gross pool. At gross pool it would inundate about two miles less river and the effect on whitewater activities would be about the same as the authorized New Melones Lake. Required flood storage space of 450,000 acre-feet would result in more extreme vertical drawdown than for a 2,400,000 acre-foot reservoir. Water supply yield would be reduced, resulting in a corresponding reduction of a ll water use benefits including' water conservation, water quality, power, and fish releases. With the 1,100,000 acre-foot reservoir, virtually a ll the historical and archeological sites would be Inundated. The beneficial aspects of such a reservoir are that about two miles less river and about 4,800 acres less land v^ould be inundated than with the larger 2,400,000 acre-foot reservoir. The 1,100,000 acre-foot plan was subsequently modified by water supply studies indicating_that.incrementa1_ net benefits increased with the size of~ reservoir"jp to the elevation that—the-new-Stanislaus powerhouse would be Inundated. ThTs~restrlted-----_ in the~plan for a 27500^000 acre-foot capacity reservoir.

c. A reservoir having a capacity of about 1,500,000 acre-feet could be operated to provide about the same flood control, water quality, recrea­ tion and downstream fis h e ry b e n e fits as the authorized New Melones Lake project. Such a project is estimated to cost about $100,000,000. It would result in the loss of the existing Melones powerplant and would forego the development of the hydroelectric and water conservation potential of the site. A new 1,500,000 acre-foot reservoir would inundate a ll but about one mile of the whitewater boating area. Such a project is estimated to have a benefit-cost ratio of less than 0.9 to 1 and therefore would not be economi­ cally justified.

d. Reservoir sizes larger than the adopted 2,400,000 acre-foot plan were considered but not recommended because a larger reservoir would inun­ date the Pacific Gas and Electric Company's Stanislaus powerhouse. Replace­ ment of the powerhouse together with greater costs of the larger reservoir would raise the cost of the project far more than the benefits to be derived from a larger reservoir. It was determined that it would be more expensive to construct the larger reservoir in stages than to construct the fu ll capacity at one time. Also, constructing a smaller reservoir with provisions for subsequent enlargement to 2,400,000 acre-feet would defer urgently needed functions and benefits. a. Channel and le v e e Improvements. - These improvements could be constructed to provide some degree of protection to the 35,000 acres of highly developed agricultural land along the Stanislaus River. Levees to control a once in 50-year flood frequency of 70,000 cubic feet per second would cost in the order of $53,000,000 to construct. Levees to control a once in 100-year flood frequency of 110,000 cubic feet per second would cost about $70,000,000 to construct. These costs are based on pro­ viding an efficien t flood carrying fa cility in which only a minimum amount of vegetation would remain. The plan would also result in potential reclama­ tion of all riparian lands not included within the levees. The costs do not include maintenance costs, mitigation costs for eliminating large amounts of prime riparian vegetation or costs of acquisition of fish habitat, or implementation of one of the alternatives for w ildlife and public access to be implemented on the lower Stanislaus River. In addition to destroying much of the remaining natural environment along the Stanislaus River, the levees would not aid in protecting 235,000 acres of developed land along the San Joaquin River, nor would the other benefits of the New Melones Lake project be achieved including power generation, irrigation yield, water quality control, fish enhancement, and recreation.

Advantages of a channel and levee project would include prevention of flood damages along the Stanislaus River, and preservation of the whitewater boating area and several caves and various historical monuments and sites described in paragraph 21.

b. Flood p la in management. - This a lte rn a tiv e would requ ire curtailm ent of development and/or flood proofing of structural developments in the flood plain. Such a program would be inadequate as an alternative to New Melones Lake since most flood damages in the lower Stanislaus and San Joaquin Basin are agricultural and would not be prevented by a flood plain management program. Flood damage reduction would not be significant, and other benefits provided by reservoir storage would be foregone.

c . Abandonment of the project. - If construction of the project was stopped and the development abandoned, the existing Melones Reservoir and powerplant would continue to serve the needs of the Oakdale-South San Joaquin Irrigation Districts and a Pacific Gas and Electric powerplant of 26,000 kilowatt capacity. There would continue to be only nominal recreation use at the existing reservoir. The area would be expected to remain su b sta n tia lly unchanged except fo r continuation o f normal development in the foothill area (see section II for description). The archeological sites would not need to be excavated and the whitewater boating area would continue to be available. Fish spawning gravels would continue to be removed. Downstream flood damages would continue to Increase and the agricultural benefits which New Melones w ill facilitate through new irrigation water would be foregone. Benefits from water quality improve­ ment, fishery improvement and other benefits associated with the new water made available for use as needed, would be foregone. It is also possible that the Oakdale and South San Joaquin Irrigation Districts, or other interests, would attempt to increase the size of their existing Melones Reservoir to conserve additional water. If the project construction was abandoned at th is time, the Federal investment to date o f about $28 m illio n would be forfeited (see paragraph 10).

44. Alternatives to the planned operation. - New Melones Lake project authorization provides that on completion of construction, the project w ill become an integral part of the Central Valley Project and be operated by the Bureau of Reclamation. Under the planned operation, the yield of New Melones Lake would be diverted from either the reservoir or Stanislaus River to meet municipal, industrial and irrigation water requirements in the local areas, prospective adjacent service areas, and other Central Valley Project service areas.

In conformity with the Authorizing Act, P.L. 87-874, water w ill not be diverted from the Stanislaus River Basin in connection with the opera=~~ troiTof the Central Valley Project until the Secretary of~the Interior has determined the quantity ot water needed to satisfy existing and future needs~vltKIn that basing following secretarial determination, the diver­ sions which are made w ill give fu ll recognition to the in-basin needs as determined. This determination w ill recognize a ll existing water rights as well as the existing and projected requirements for water supplies in the areas adjacent to Stanislaus River which need to rely on water supplies from that source.

In determining the needs and plan of service for Stanislaus River water in the adjacent areas, other facilities and sources also w ill be considered - including , East Side Division, and the Mokelumne, Calaveras, and Tuolumne R ivers. W ithin the areas adjacent to Stanislaus River - comprising portions o f Calaveras, Tuolumne, San Joaquin and Stanislaus Counties - a significant requirement for New Melones water is expected to develop and w ill need to be satisfied.

The remaining water conserved by New Melones Reservoir w ill be supplied to other Central Valley Project service areas needing and willing to con­ tra c t fo r such water su pplies. One p o te n tia l place o f such use is the east side of the San Joaquin Valley where a large demand exists for addi­ tional water for lands now under irrigation. Alternatively, this remaining portion of the yield could be released downstream-supplementing the fishery and water quality releases, and integrated with yield from other CVF reservoirs to effectively meet the demands o f other s e rv ic e areas e ith e r d ir e c t ly or in d ir e c tly ; such as Folsom South, Delta-Mendota, San Luis, San Felipe, Contra Costa, and the Sacramento-San Joaquin Delta including the Bureau's share of protecting and enhancing the water quality in the Delta.

These alternative operation plans may be either a long-range project purpose or implementated for an interim period before fa cilities are available or water requirements have built up for consumptive use of the yield, and means other than dilution have been implemented to maintain the water quality in the Stanislaus-San Joaquin River and the Delta. ______

Prior to initiation of the operation of the conservation function of ^ the reservoir, the Bureau of Reclamation w ill prepare and have on file 1 with the Council on Environmental Quality, a supplementary environmental \ statement covering the impact of operating New Melones Reservoir and use.X 'of its water supply. ^ SECTION VI - RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF THE ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY

45. Long-term productivity - The cumulative effect of the project, and developments that it w ill stimulate such as possible diversion dams, canals, urban and recreational expansion and new irrigation lands placed into production w ill likely accelerate the reduction of available w ildlife habitat. Similarly, there would be a net reduction of riparian vegetation.

Evaporation, stratification and recreation at the lake, along with increased effluent from urban and agricultural areas, w ill result injiet ~~ water-quality—degradation, although established water quality standards are expected co be met. Reregulation of flows w ill jeduce peak winter flush*ng flnwg^ important to the long-term productivity of the Delta and bays; the flushing flows w ill continue as lesser controlled flows during flood control operations of the reservoir. The volume contributed by the Stanislaus River for Delta flushing flows is not great, especially when compared with the Sacramento R iver. However, the cumulative e ffe c t o f e x is tin g impoundments, along with those under construction and planned fo r future construction in the Central Valley, has a significant adverse impact on the continued productivity of the Delta and bays; this aspect is under consideration by the California State Water Resources Control Board as exemplified in their recent Decision 1379.

The unusual experience of whltewater boating along the Stanislaus River w ill be foregone to future generations after the project is in operation. Also, some caves and archeological sites w ill be inaccessible.

New Melones Lake w ill result in long-term productivity for certain commodities as a trade-off or exchange of existing commodities. Flood protection w ill safeguard human life , health and property. Electric power generation w ill provide a smog-free source of power for present and future generations. The conservation yield w ill meet the needs of municipal water supply and assist in meeting the projected needs of water for irriga­ tion, particularly in areas that are presently experiencing serious over­ draft of ground water resources. The large lake and lands acquired would provide recreational opportunities for large numbers of people. A unique feature is the caves and natural bridges in the area. Recreation plans for the lake w ill recognize the value of such features for public use and scientific study.

Some water w ill be stored and released to control dissolved oxygen in the Stanislaus River and total dissolved solids in the San Joaquin River - to maintain them at specified levels for water quality control purposes. The project w ill also provide minimum releases for anadromous fish and other species. This w ill result in considerable enhancement, and, perhaps more significantly, w ill assist greatly in assuring that this resource w ill be preserved for future generations.

The control of floods w ill cause a further reduction in the natural process whereby soil nutrients are replenished through periodic flooding and s i l t d ep osition . This would be more than compensated by the addition of fertilizers and crop rotational practices.

A multipurpose project such as New Melones Lake cannot avoid being controversial, for -it affects many individuals and interest groups. For some, it w ill maintain and enhance long-term productivity while for others, it w ill modify or destroy existing long-term productivity. To partially offset the damages that would be caused to existing long-term productivity, a specific w ildlife management area w ill be acquired at the project, and plans are proceeding to acquire rights to riparian lands that are valuable fo r fis h and w i ld lif e and other purposes downstream o f the p ro je c t. These riparian lands are presently being reduced by conversion to agriculture, without the project and in spite of flood hazard. Acquisition of these lands would ensure their continued availability as a natural resource fo r enjoyment by future generations. A lso, spawning gravels downstream would be acquired and, if feasible, an existing whitewater reach w ill be improved to provide whitewater boating opportunities for "slalom" and "downriver" activities.

46. Short-term effects. - Acquisition of privately-owned lands required for the project w ill result in a short-term decrease in county tax revenue. This w ill be offset by the long-term beneficial economic impact of the project on the two counties, resulting from increased value of land and expenditures for local goods and services by the increased number of recreationists.

Possible turbidity in Tulloch Reservoir, noise from project construc­ tion, and any air pollution from burning during reservoir clearing opera­ tions would sim ilarly be short-term in nature. SECTION V II - IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES SHOULD THE PROJECT BE CONTINUED

47. Ir r e v e r s ib le and ir r e tr ie v a b le commitments. - About 10,700 acres of land containing about 1,000 acres of riparian vegetation w ill be inun­ dated in addition to the area inundated by existing Melones Reservoir. About 14 miles of river used for whitewater boating w ill be eliminated for as long as the project exists. Also, the upstream trout fishery w ill be displaced. Several historic sites w ill be inundated, together with any archeological artifacts not removed during the planned excavations. Existing Melones Dam and Pacific Gas and Electric Company's Melones powerplant w ill be made inoperable. Acquisition of spawning gravel for preservation of fishery resource in the lower Stanislaus River w ill deprive gravel companies operating in the area of this supply. Certain caves w ill be flood ed and ir r e v e r s ib ly damaged. About 16 m illio n cubic yards o f rock w ill be moved and used to construct a dam. Some scenic losses w ill result. SECTION V III - COORDINATION WITH OTHERS

48. Public participation. - There has been close and continuing public participation in development of the plans for New Melones Lake, both during the preauthorization feasibility report stage, and the post­ authorization advance planning and design stage. Prior to the District Engineer submitting his recommendation for the construction of the New Melones Lake Project, aJpublic~Kearing on the proposed project was held in Modesto on 17 0ctobecLl960.^rhls hearing was conducted jointly by the District Engineer and the Regional Director of the Bureau of Reclamation, About ISO people attended the hearing, many of whom submitted testimony concerning the proposed project. On 16 June 1961, a public notice was issued stating the recommendations of the District and Division Engineers and affording interested parties an opportunity to present additional information concerning their views on the project to the Board of Engineers for Rivers and Harbors during processing of the report to Congress for authorization.

During the current advance planning, design, and construction phase, there have been several additional public meetings held locally for the purpose of providing fu ll information to concerned members of the public. The primary purpose of these meetings was to provide information about the real estate acquisition procedures for the project and to obtain the views of the public concerning acquisition of the w ildlife mitigation lands at Peoria Mountain. Several meetings were held for real estate matters and three meetings were held in Sonora, California, regarding the w ildlife mitigation lands in 1966 and 1967.

The most recent public meeting was held in Modesto on 2 March 1972, as discussed elsewhere in the statement. Also, numerous special meetings have been held, including the following:

(1 ) In itial meeting with whitewater representatives in District o f f ic e to obtain data on whitewater use (c ir c a October) 1971.

(2 ) Meeting with Environmental Defense Fund and Sierra Club representatives in District office to discuss various environmental problems associated with New Melones, 24 November 1971.

(3 ) Meeting in South Pacific Division Office with Environmental Defense Fund representatives to discuss their objections to New Melones p ro je c t, in la te 1971.

(4 ) Meeting with San Joaquin County Advisory Water Commission in Stockton to discuss environmental aspects generally, 23 February 1972. (5 ) Meeting with vhitevater representatives at Berkeley to discuss whitewater mitigation possibilities, 28 February 1972.

(6 ) Meeting with Yokut Wilderness Group of the Sierra Club in Modesto regarding various environmental aspects of New Melones project, 29 February 1972.

(7 ) Meeting with whitewater coupetition experts on the Kings River to discuss development of a competition kayak run on the lower Stanislaus R iver, 1 A p r il 1972.

(8 ) Meeting with Oakdale and South San Joaquin Irrigation Districts to request release of 350 acre-feet of their storage for kayak te s t run below Goodwin Dam, Oakdale, 13 A p r il 1972.

(9 ) Meeting with whitewater competition experts on on same subject as above, 22 April 1972.

(10) Whitewater raft trip by District Engineer and staff members with Sierra Club group, Stanislaus River, from Camp Nine to Parrott's Ferry Road, 29 April 1972.

There have been numerous additional public contacts through smaller, more informal meetings, correspondence, telephone calls, and occasional news releases. The dissemination of information about the project in this manner has been extensive and was intended to provide fu ll information concerning the project to the public.

Another public meeting is planned for late 1972 to present the tenta­ tively selected plan to be implemented by the Corps of Engineers on the lower Stanislaus River downstream from Goo&in Dam. Views and additional information obtained at this meeting w ill be considered in preparing the recomnended plan fo r adoption. Upon adoption, the plan w i l l be ca rried out on a schedule commensurate with the overall schedule for construction of the project. Additional public meetings presenting information on real estate acquisition and other features of the plan w ill be held.

49. Governmental agencies. - The draft environmental statement was sent to the following agencies and local governments requesting their views and comments. Th eir comments are summarized in appendix A, along with the Corps of Engineers responses to them, and copies of the replies are attached to the environmental statement. Environmental Protection Agency Calaveras County Department o f In te r io r Tuolumne County U. S. Forest Service Stanislaus County U. S. Soil Conservation Service San Joaquin County Department o f Commerce South San Joaquin and Oakdale State of California Irrigation Districts C ity o f Modesto

50. Citizens groups and others. - There has been coordination with environmentally-oriented citizens groups and commercial whitewater boating coopanies during the process of evaluating the environmental impact of this project. The Yokut Wilderness of the Sierra Club, the National Speleological Society, and the American Biver Touring Association have been particularly helpful in providing information on the natural values of the project area and the Stanislaus Biver below the damsite. Copies of the Draft Environmental Impact Statement, with a specific request for comments, were furnished to the groups listed below. In addition, copies of the Draft Statement were furnished to many Individuals who expressed an interest in it.

Environmental Defense Fund S ierra Club - National o f f ic e Sierra Club - Yokut Wilderness Group Stockton Audubon Society National Speleological Society C itizen s Environmental Advisory Committee The W ildlife Society - Sacramento Chapter American Biver Touring Association Wilderness World

51. Unreconciled conflicts. - Although considerable discussion and attenpts at resolving the controversial environmental concerns connected with this project have been made, several concerns remain unresolved. The following is a discussion of the most important of these. One of the primary unreconciled conflicts is that of using the Stanislaus Biver from existing Melones Beservoir to Camp Nine in its existing state for whitewater boating and other uses versus inundation of this reach to achieve the other economic, social, and environmental benefits discussed in this EIS.

Another unreconciled conflict concerns the use of the new conserva­ tion yield of 285,000 acre-feet annually to be made available from New Melones. The studies made for project feasibility were based on using the water in the Stanislaus Biver Basin and diverting surplus waters to the southern San Joaquin Valley via proposed works of the Central Valley Project. Environmental groups have voiced opposition to further diversion of water from streams draining into the Central Valley without firs t assuring that water quality needs in the Sacramento-San Joaquin Delta w ill be met. The environmental groups cite Decision 1379 of the California Water Resources Control Board of July 1971, which sets forth water quality criteria for the Delta for the purpose of maintaining environmental quality, particularly repulsion of salt water, in the Delta. Insofar as the State Delta Standards can be evaluated, the net Delta outflow requirements in a normal year are about 2.9 million acre-feet. To meet this requirement, about 1.6 million acre-feet of additional outflow from the Delta to San Francisco Bay would be required (normal water year). Decision 1379 states that this would require the use of storage in existing or future water resource developments in the amount of 500,000 acre-feet voider the conditions of development expected by the year 1990 (65). The environmental groups contend that additional diversions from Central Valley streams away from the Delta w ill create a need for additional water resources development to provide for water quality needs and that this could lead to increased feasibility for development of streams on the north coast of California. The north coast streams contain very valuable environmental resources that w ill be affected by water resource development. Until Decision 1379, it had been understood that north coast developments could be deferred for many years. Although Decision 1379 does not apply directly to New Melones Lake project, consideration of Decision 1379 has led to a reexamina­ tion of the previously planned additional diversions with a view to providing the water that is needed in the Delta as a first priority before diverting additional flows from Central Valley streams elsewhere. The legality of Decision 1379 is subject to legal review and litigation and a final decision w ill not be kncwn for some time. With respect to New Melones, it appears that the additional water supply of 285,000 acre- feet annually w ill be needed either for irrigation, municipal and industrial supply and/or for water quality purposes in the Delta. As pointed out in paragraph 30, up to 70,000 acre-feet of the conservation yield is already available under the water quality function of the project. These water quality flews were planned for recapture for irrigation purposes after serving their water quality purposes. The entire water supply could be used for water quality in the Delta and a ll or part of this s till be utilized for Irrigation after flowing to the Delta, then being diverted by means of transshipment via the existing canals and pumping facilities at Tracy and/or by additional facilities. This would also assist in clearing up the dissolved oxygen "block" at Stockton that is detrimental to anadromous fish (paragraph 17). However, use of water from New Melones for irrigation or for water quality purposes in the D elta remains an unreconciled c o n flic t . The Corps o f Engineers has no water rights to the flews in Stanislaus River and cannot provide a solution to this problem. The Bureau of Reclamation may consider this prospect in their operation of the project. The California State Water Resources Control Board administers applications, permits, and licenses to appropriate water and acts in conjunction with the courts in the adjudication of water rights. Representatives of the Environmental Defense Fund and other environ­ mental groups consider the need for development of a new irrigation water supply to be an unresolved conflict. They cite two reports (66) (67) which allege there w ill be serious excess acreage problems for many crops if development of new Irrigation supplies continues, stressing the conflict between Federal farm subsidy programs and Federal development of irrigation water. The Environmental Defense Fund representatives state that much of the new irrigation water from New Melones would be utilized for crops which are presently receiving subsidies. They also believe that new irrigation water supplies in the Central Valley would lcwer prices of some crops, such as oranges, and make other areas presently growing these crops, such as the southern California coast, unable to compete. This is d ifficu lt to assess since the Bureau of Reclamation has not yet determined the service area(s) where the conservation yield w ill be used. See discussion in paragraph 4. NEW MELONES LAKE ENVIRONMENTAL IMPACT STATEMENT

APPENDIX A

COMMENTS AND RESPONSES

U. S. Army Engineer District Corps of Engineers Sacramento, California APPENDIX A

COMMENTS AND RESPONSES

TABLE OF CONTENTS

Paragraph Subject Page

1 ENVIRONMENTAL PROTECTION AGENCY A-l 2 DEPARTMENT OF INTERIOR A-2 3 U. S. FOREST SERVICE - DEPARTMENT OF AGRICULTURE A-8 4 SOIL CONSERVATION SERVICE - DEPARTMENT OF AGRICULTURE A-10 5 DEPARTMENT OF COMMERCE A-ll 6 CALAVERAS COUNTY A-l 2 7 TUOLUMNE COUNTY A-l 2 8 STANISLAUS COUNTY A-l 2 9 SAN JOAQUIN COUNTY A-l 2 10 SOUTH SAN JOAQUIN AND OAKDALE IRRIGATION DISTRICTS A-l 2 11 CITY OF MODESTO A-16 12 ENVIRONMENTAL DEFENSE FUND A-l 7 13 SIERRA CLUB (EXECUTIVE DIRECTOR) A-46 14 YOKUT WILDERNESS GROUP, SIERRA CLUB A-52 15 STOCKTON AUDUBON SOCIETY A-54 16 NATIONAL SPELEOLOGICAL SOCIETY A-57 17 CITIZENS ENVIRONMENTAL ADVISORY COMMITTEE A-60 18 THE WILDLIFE SOCIETY, SACRAMENTO CHAPTER A-60 19 AMERICAN RIVER TOURING ASSOCIATION A-61 20 WILDERNESS WORLD A-62 21 STATE OF CALIFORNIA A-66 22 ENVIRONMENTAL DEFENSE FUND, ET AL (ADDITIONAL A-72 COMMENTS) APPENDIX A

COMMENTS AND RESPONSES

1. ENVIRONMENTAL PROTECTION AGENCY

(1) Comment: The use of the 325,000 acre-feet of potential Irrigation water is a source of major controversy surrounding the New Melones Lake project. Since it is not yet certain where this water will be used, it is not clear that the agricultural runoff will be lew in salt content. The salinity of agricultural runoff depends on the salinity of the soil and the salinity of the water used for,irrigation. ,For example, hi$i salt soil in the Coachella Valley is a major cause of the serious salinity problems of the Salton Sea. The impact statement should discuss the soil quality of the probable irrigation sites to support the comment that agricultural runoff will not be a significant environmental impact.

Response: The water may be used almost anywhere within the San Joaquin Valley, since most of the valley is within the existing or anticipated future service area of the Central Valley Project of the Bureau of Reclamation. Most of the new water will be used in areas already being irrigated by water pumped from groundwater sources and will be used in lieu of punped water, which is currently overdrafting the groundwater supply. There are no known Irrigated or irrigable areas in the San Joaquin Valley which produce or would produce a salinity problem comparable to that existing in the Coachella Valley.

(2) Comment: As stated in Section V - Alternatives, on page 81 under Alternatives to the planned operation: ". . .the new water yield from New Melones could be utilized for releases to the Delta to meet recently established objectives of the California Water Resources Control Board in their Decision 1379 dated July 1971 which set forth minimum Delta flow requirements for the purpose of maintaining environmental quality in the Delta."

However, discussion of an operation schedule designed to help meet the requirements of Decision 1379 was not included, nor was information nrnvlripri nq the amount- of water from New Melones that will actually flew tJTroughj^je^JJelta as part oi tne'T.b filllJT&fl ACffe-ieet requirement ol the Decision. With ~the inclusion of this information in the impact statement, the irplications of this alternative can be further evaluated.

Response: A discussion of this has been included in para­ graph 51.

NOTE: Pages and paragraphs in Comments refer to Draft EIS. Paragraphs in Responses refer to Final EIS. 2. DEPARTMENT OF INTERIOR

In addition to five introductory statements contained in their letter, the Department provided the following 17 specific comments:

(1) Comment: Throughout the December 1971 draft environmental statement, reference is made that the New Melones project will yield 325,000 acre-feet of water annually. Our best estimate for the past several years is 285,000 acre-feet annually. It is Important to note that our reduced figure does not include1 atiy yield for water quality releases. Therefore, our figure must be further reduced. This apparent discrepancy needs clarification in the final environmental statement as the estimated amount of water available annually and its use are the bases for assessing environmental impacts. We believe the annual water yield should be considered a conservation yield rather than simply irri­ gation since a portion will be used for municipal and industrial purposes.

Response: The correct figure for conservation yield is now used throughout the EIS and it is clearly stated also that this includes water for water quality control purposes. It is noted that all or part of the water for water quality enhancement in the lower San Joaquin River could still be utilized for irrigation below Vernalis or in the Delta if not required for additional water quality needs in connection with Decision 1379 of the State Water Resources Control Board.

(2) Comment: Under the discussion of Project purposes, pages 3-5, we believe it desirable for the final environmental statement to recognize that the Secretary of the Interior will be responsible for determining the quantity of water required to satisfy anticipated future consumptive water uses within the basin before exportation of any water made available by the New Melones project. It is not necessary that the East Side Division be coupleted as there are now Central Valley Project irrigation service areas in which any available waters can be used effect­ ively on an interim basis.

Response: Concur.

(3) Comment: Although considerable attention is given to des­ cribing adverse impacts and potential means to mitigate such Impacts, we are concerned that serious attention will not be given to unresolved problems. For example, the statement in the Summary and on page 1 that:

"The construction contract for the dam and spillway is scheduled to be awarded about 1 June 1972, if adequate funds are available." "If the alternative of no action were decided upon at this time, the Investment of about $20 million which has been committed in construction of the New Melones project would be forfeited." are not conducive to adequate discussion of environmental impacts.

We believe the Decenfcer 1971 draft is Inadequate in several aspects which need discussion in the final statement.

Response; The discussion of unreconciled conflicts is in accord with instructions of the Chief of Engineers on preparation of EIS as approved by the President's Council on Environmental Quality. This discussion serves as an environmental full disclosure mechanism by citing those areas where agreement on pertinent environmental issues cannot be reached. Discussion of the schedule for the dam contract and expendi­ tures to date are considered appropriate in that context and have been retained in the statement. One purpose of the Draft EIS, with review and comaents by others, is to Insure that appropriate consideration is given to all factors and to insure comprehensive Interdisciplinary response.

(4) Concent: Only passing and scattered reference to minerals in the project area has been made. The authorized New Melones Reservoir will flood a substantial portion of the Mother Lode area which was the site of the California gold rush of 1849 and 1850. The Bureau of Mines originally reviewed the project in 1962. At that time it was concluded that overall benefits of the project justified foregoing additional mineral development. Essentially this position still appears valid. However, the draft environmental statement does not adequately consider potential ^

Response: The area in the foothills of the Sierra Nevadas / containing a concentration of gold and other valuable minerals, often / referred to as the "Mother Lode," is about 120 miles long. About one / mile of this length will be Inundated by New Melones Lake. Although / difficulty in extraction of minerals in this limited area affected / by inundation may be Increased, it is considered that there will be / no irreversible commitment of resources. Additional Informational mineral resources and their importance has been added to the EIS.

(5) Comment: The project boundaries include 16 mines with significant past mineral production. Over 40 mines are within one mile of the project boundary where a full reservoir would present flooding hazard for present and future underground workings. It is further empha­ sized that active mining of this area stopped in 1942 because of War Production Order L-208 and not because of exhausted ore reserves.

Response: Some mines and prospects that are part of the Carson Hill mining area will be inundated. Access to these mines is from tunnel portals and open cuts at the top of the hill outside the project boundaries. The tunnel portals will be closed with impervious material and access to remaining mineral bearing rock will still be available from private land outside the project boundaries. This matter will be considered in more detail in the New Malones Lake Clearing Design Memorandum. Known mineral sources in the project area include several old marble quarries and some prospects (mines that were nonproductive) in upper reaches, and the mines and prospects in the vicinity of Carson Hill or Bostick Mountain area. These may total 16 but do not contain minerals of quantity sufficient to make it economically feasible to mine at the present time or in the foreseeable future. After War Produc­ tion Order L-208 was rescinded, it was not found to be economically feasi­ ble to operate most of the mines in the area. The mines outside of the project area would not be significantly affected by the project since most of them are above gross pool.

(6) Comment: The project area has been expanded since 1962 and now appears to contain two chromite mines and one asbestos mine which have been productive. Chromite is a strategic and critical commodity. If these mines are within the project boundary, the final environmental statement extraction would or would not be corp*f

Response: The chromite mines are in the Bostick Mountain area and will not be inundated. If mineral deposits on project lands become critical to the National well-being, arrangements could be made to mine resources of such significance. Although the cost of mining this area could be increased, the resource commitment would not be irretrievable. The sketch furnished did not accurately show the project boundaries and is undoubtedly the reason for the discrepancy on the nunber of mines in the project area. The asbestos mine noted on the sketch map is not located within the project area. Evaluation of the asbestos mine opera­ tion introduces a significant factor affecting mining in this and other areas, i.e. increased costs for environmental protection. The existing asbestos spoil pile is a visible degradation to the scenic aesthetics of the area's natural resources and perhaps other environmental components. Future operations of this kind will become uneconomical since the costs of avoiding adverse environmental effects may be prohibitive. (7) Comment: The draft statement does not discuss impacts associated with transmission lines required to distribute the power generated at the New Melones project.

Response: Discussed in paragraph 32 of the final EIS.

(8) Comment: Soil and geologic structures in Tuolume and Calaveras Counties are such that adequate garbage and sewage disposal are difficult. The final statement would be improved with an expanded discussion of how these problems will be solved for permanent habitations and related support facilities required for project operations personnel and for the expected influx of people seeking recreation opportunities. In the same context, are local community services, e.g., schools, police and fire protection adequate to meet the needs of the expected project work force?

Response: Impact of construction workers on community services is discussed in paragraph 34. Solid and liquid waste treatment facilitieF to be provided as part of the project to accommodate antici­ pated recreation use will be detailed in the master plan.

(9) Comment: While the draft environmental statement gives considerable attention to significant recreation, wildlife and fishery values, the draft environmental statement does not describe net impacts. For instance, on page 40, the statement is made that, "The problem of finding a reasonable method for mitigating for whltewater (recreation use) has received considerable study and will continue to be investigated. Several approaches are being investigated. . ." On pages 26, 27, and 75, reference is made to caves having possibility of national or statewide significance, yet the draft statement does not identify whether the caves adversely affected have any significance, nor are any mitigative or protective measures recommended.

Response: These aspects have been expanded in the final EIS— see paragraphs 27, 28, and 29— addressed in response to some comments by the Environmental Defense Fund and the National Speleological Society task force.

(10) Comment: The discussion of the Bostick Mountain area (page 6) is misleading in that the State of California and the Bureau of Sport Fisheries and Wildlife have not yet determined its wildlife manage­ ment potential. Of a more technical nature, we prefer the word "mitigate" wildlife losses rather than "offset" wildlife losses .(pages 61-62).

Response: As a result of current studies for the master plan, it has been decided to make the Bostick Mountain area available for wildlife uses. If coordination indicates that such use is not desired, the area will be designated for other uses. This aspect and the use of the term "mitigate" has been clarified in the EIS.

(11) Comment: We also understand that the damaging effects of blocks of oxygen-deficient water extends downstream a considerable distance below Ripon. The final environmental statement should consider this, as well as the effect on the fishery should the concentration of oxygen fall below the 85 percent saturation median during critical stages of the life cycle of fishes inhabiting the Stanislaus River downstream from the New Melones project.

Response: Concur. Information has been included in paragraph 16 of the EIS.

(12) Comment: The attractive appearance of Bermuda grass in the unsightly reservoir drawdown zone is important. However, this grass has questionable wildlife value. We believe some other plant could meet the aesthetic needs and better meet wildlife and fish requirements. We also wonder, if it would be possible to use vegetation removed from the reservoir site for mulch rather than burning as proposed on page 69. The Bureau of Sport Fisheries and Wildlife would be happy to cooperate with the Corps in considering this aspect of the project.

Response: Research is being conducted to find vegetation that can withstand various degrees of inundation. Selection of vegetation to be planted would be in accord with the primary use of the area, i.e., recreation, wildlife, or other. Only selected vegetation will be removed. Virtually no vegetation will be removed from the fish management areas. Converting the removed vegetation to a mulch is more expensive then burning. If there are substantial environmental benefits, and no important detriments such as water quality problems, conversion of the vegetation to mulch may be justified. Coordination with the Bureau of Sport Fisheries and Wildlife will be continued on this matter.

(13) Comment: The draft environmental statement touches only lightly on potential Impacts on the Delta. This is a significant item and should be expanded in the final statement including anticipated diversions and return flows under project conditions and particularly inpacts on the fishery, water quality and recreation during drier water years.

Response: The inpact on the Delta is discussed in greater detail in the final EIS and additional discussion can be found in responses to various comments. EDF comment 45, for example, deals with this matter.

(14) Comment: The discussion of alternatives would be improved if the final statement considers provision of recreation facilities together with Improved public access to the existing Melones Reservoir. Also we are aware of estimates as high as 40,000 people running the white- water rapids to be Inundated by the New Melones Reservoir and that this type of recreation use is Increasing rapidly. We, therefore, suggest that accurate use and an estimate of projected use be sought and included.

Response: Although major alternatives to the project are discussed in the EIS, numerous variations to Incremental portions of the project are possible, including the suggestion above. Although the Corps of Engineers has no authority to provide public access and recrea­ tion facilities at the existing reservoir, such developments could be provided by other interests. Federal and State grant and loan funding programs are available, generally on a matching basis and requiring guarantees for operation and maintenance. Preliminary estimates by the Corps of Engineers indicate that n&ximum practical use for the existing / reservoir would be in the order o f 5MILM 0 recVfiatiOfl HaytS annual 177 "* costiHg iboufc $2,750,000 discounted to present worth (ly/2 prices77- This does not include tHe cost of providing access. Rafting and boating trip use and total recreation use on the river in the whitewater reach are estimated by tKe EnvTronSntaTDeTense^tffrd (EDF) at 23,000 recreation days and 68^000>irecreaj^rj^ws, respectively, for 1971. No-usg, data has been collected on these activities by the Corps of Engineers. EDF es^ma£sa^£ha-4**«l-^M«-^f*Up-4^fluR£a^J2^iectedaa90J|00^j^xEe^^S|i!jll2 s by~l580; however, as noted in response toEbF comment timber 37, it appeSTS" unreasonable to expect this use to reach that level without con­ stituting over-crowding of the very limited area and the possibility of degrading or destroying the wilderness experience sought. Data sub­ mitted by EDF, the Bureau of Sport Fisheries and Wildlife and others has been used in the evaluations.

(15) Comnent: The final environmental statement needs a better analysis of short- and long-term uses of the environment and the maintenance and enhancement of long-term productivity. Discussions pertaining to irrigation and municipal and industrial water use should be coordinated with the Bureau of Reclamation.

Response: Concur. Section VI of the EIS has been revised. Discussions of irrigation, municipal and industrial water use have been coordinated with the Bureau of Reclamation. However, the degree to which operation of the conservation yield, in conjunction with other project purposes, may affect the analysis cannot be completely analyzed until com­ pletion of a firm reservoir operation plan by the Bureau of Reclamation, presently scheduled for late 1972. Additional information on this will be included in the EIS when updated by the Corps of Engineers and in the EIS to be prepared by the Bureau. (16) Comment: Page 61 Infers that 100,000 acres of new Irri­ gated land will be brought into production. Since water from the New Melones project is intended primarily to replace ground water supplies now being overmined, it is unlikely that there will be any significant amount of new irrigation. This aspect should be clarified in the final statement.

Response: This has been clarified.

(17) Comment: We understand that your office as recently as March 9, 1972, has been conducting meetings with local residents and officials to resolve these important environmental matters. Until ultimate adverse environmental impacts of the project are more fully defined, constructive comments can be only speculative. We believe the final statement needs careful elaboration on these points. Agencies of this Department stand ready to assist in that endeavor.

Response: The public meetings have been instrumental in narrowing the range of alternatives considered for environmental miti­ gation or preservation. Adverse environmental effects have been stated in the EIS. Commitments for protective and mitigative measures are included although final details are not established in all cases. When these measures are implemented together with the overall features of the project a net beneficial inpact on the environment will result. This EIS will be revised periodically to reflect changes and include new data.

3. U. S. FOREST SERVICE - DEPARTMENT OF AGRICULTURE

(1) Comment: The statement appears somewhat weak in proposing positive measures, programs, and acceptance to assure minimum adverse environmental impacts, for example see page 55-56. Areas could be developed to improve wildlife food conditions to help overcome wildlife losses. People could be restricted from some areas Including possibly some of those shown for recreation development. Sub-inpoundments could be constructed within the reservoir for fisheries and wildlife.

Response: This comment apparently referred to page 65 and 66 of the draft EIS. Methods that could be used for improving food con­ ditions for wildlife are discussed in paragraph 33c. A general plan for wildlife management will be developed in cooperation with the Bureau of Sport Fisheries and Wildlife and the California Department of Fish and Game. Specific management measures such as those suggested will be considered further at that time.

(2) Comment: Page 76, Scenic Value Losses - ". . .drawdown will create unattractive belts of non-vegetated land . . . Such zones are typical at all multi-purpose and irrigation reservoirs." The question here is . . . need they remain so? Perhaps some development could enhance this eyesore.

Response: As discussed on page 74 of the draft EIS, vegetative research at University of California at Davis sponsored by the Corps, and experiments conducted by the Corps at New Hogan Lake may assist in alleviating drawdown appearance at New Melones Lake.

(3) Comment: We have found no effect on the migration of game animals from National Forests within the influence zone of the reservoir.

Response: None needed.

(4) Comment: In order to assure that the water flowing into the reservoir from National Forests is of useable quality the overall policy (Forest Service Manual 2543.03) of the Forest Service requires that ". . . National Forest land management practices are conducted in a manner which will ensure a quality water yield suitable for its Intended purpose." Also, ". . . The Forest Service will cooperate with the department of Health, Education, and Welfare and with States, counties, and municipalities having jurisdiction over water for the purpose of ensuring safe supplies for domestic and recreation use and preventing and controlling water pollution from waste disposal."

Response: This statement has been included in paragraph 30.

(5) Comment: It is indicated that certain fisheries studies pertaining to the project are underway and their results not yet available. We assume some "open end" arrangement is made to incorporate these findings into the Environmental Statement when they are completed.

Response: These have been included in paragraph 31.

(6) Comaent: What assurance will be given that the minimum flows released for flshlife will be utilized for that purpose in perpetuity and will not be subject to appropriation for other uses? If they are incorporated as beneficial aspects of the cost-benefit ratio, we assume that they have some degree of permanence.

Response: Ihe Bureau of Reclamation will obtain the water rights for the minimum fisheries releases just as for all other water rights for this project. Once the water rights have been obtained for this purpose, that water would not be subject to appropriation unless such appropriation were found to be compatible (i.e., diverted and used down­ stream from the area needed by the fisheries).

A-9 (7) Comment? One of the major problems developing from such water developments is the provision of fisheries enhancement in downstream river stretches without adequate provision for public access to such areas. It is suggested that public access provisions be assured in the case of the Stanislaus River Designated Floodway.

Response: Public access is included in planning as dis­ cussed in paragraphs 4 and 27.

(8) Comment: Are there benefits to be obtained from providing for multiple release outlets at various elevations of the new reservoir? This may warrant investigation in relation to desired temperature regimes.

Response: The low level of the outlets at New Melones Dam will lcwer the downstream temperatures throughout the year commensurate with the fishery objectives. Studies utilizing a reservoir stratification model in conjunction with operation studies have verified this assumption and therefore no further investigations for a multi-level outlet at New Melones Dam are warranted. Costs of the multi-level outlet are presented in paragraph 30c.

* (9) Comment: The matter of screening of diversion intakes and reservoir outlets is suggested for inclusion in your analysis.

Response: Advice from the Federal and State fish and wild­ life agencies has not suggested this need. The number of fish that would pass through the outlet at New Melones Dam to Tulloch Lake would not significantly affect the fishery in New Melones Lake.

(10) Comment: The proposed "dry cycle" definition would seem to be more appropriately related to the runoff pattern of the river system under development rather than related to water deficiencies in the overall Central Valley System.

Response: The dry year definition in paragraph 31a applies to all Central Valley Project reservoirs. Since the New Melones Lake water yield will be Integrated with the Central Valley project, it appears appropriate to use the stated definition.

4. SOIL CONSERVATION SERVICE - DEPARTMENT OF AGRICULTURE

(1) Comment: Please refer to pages 69 and 70 in your statement where you have described, in a general sense, management of disturbed earth, vegetation, and other materials during and after construction. We assume that there will be definite planning and action to keep sedi­ ment out of the lake area and especially out of the tributaries and the Stanislaus River during and immediately after construction. We have in mind that sprinkling, shaping or grading, revegetation and all other related activities that would mitigate the rapid movement of sediment from freshly disturbed earth areas into the watezways. Revegetation for wildlife habitat is highly essential in a beneficial sense.

Response: The measures described are essentially included in the specifications for the Main Dam Contract. These measures have been approved by the California Regional Water Quality Control Board and the California Department of Fish and Game.

5. DEPARTMENT OF COMMERCE

(1) Comment: There is a distinct possibility that adverse environ­ mental effects will occur with the increased use of project water for agricultural, urban, and industrial development. This point, lightly considered on page 50, might warrant further consideration.

Response: Additional information has been added to the secondary environmental impact presentation in paragraph 32.

(2) Comment: The anticipated increase of a resident warm-water f i shfrrv- nnfari on page 57 wouldj>e__lnM_direct_comg^lXloflJ[£lCR_tne_Mrticiprated increase of anadromous fish runs. This competition would be for space ana fi56d. In addition, m e r e would be considerable predation on immature anadromous fish species by the warm-water species. These points may be worthy of more extensive treatment.

Response: The impact on fisheries included in paragraph 31 states that "cold water" species (trout and anadromous salmon, steelhead) will be improved as a result of colder water released from New Melones Lake. Based on advice received from the Bureau of Sport Fisheries and Wildlife, understood to have been concurred in by the former Bureau of Commercial Fisheries, since transferred to the Department of Commerce, benefit for "cold water" species will result in the decline of warm water species and this change will produce desired fishery enhancement benefits creditable to the project. 6. CALAVERAS COUNTY

(1) Comment: Py

Response: Increased requirements for county services are acknowledged in paragraphs 32 and 34 of the EIS. Both the Corps of Engineers and the Bureau of Reclamation will coordinate plans and activi­ ties with local authorities to assist in provision of the needed services.

7. TUOLUMNE COUNTY

Comments solicited but none received.

8. STANISLAUS COUNTY

No official comments were received from Stanislaus County concerning the EIS. The Board of Supervisors held a public meeting to receive comments on the EIS on 4 April 1972. At that meeting the East Stanislaus River Property Owners' Committee requested that the Board delay any action on the EIS until they had an opportunity to evalu­ ate the Impact of any proposals for the lower Stanislaus River on their members. The Board voted to honor their request. Informal views obtained from staff members of the county have been received and. although not included herein, will be considered in continuing studies.

9. SAN JOAQUIN COUNTY

Comments solicited but none received.

10. SOUTH SAN JOAQUIN AND OAKDALE IRRIGATION DISTRICTS

The comments from the districts noted that the Draft EIS was silent with respect to Impact on Tulloch Reservoir and suggested consideration of the following specific comments:

(1) Comment: Visual impact: In providing reregulation of peak water releases from New Melones Powerplant. we have been advised by the Bureau of Reclamation that the water surface elevation_in Tulloch Reservoir will -‘‘i p t T-A" -flip and elevation“SlQ-with aTffaximuo cycle of three or four days. Such fluctuation would expose an unsightly band of mud and rock below the high water line of the reser­ voir during most of the peak public-use season, a condition which the Districts have attempted to avoid except during periods of critical runoff deficiency.

Response: Tulloch Reservoir fluctuates considerably at present with operation by the irrigation districts for irrigation and power. The districts do. however, attempt to avoid fluctuation of the reservoir during the recreation season insofar as possible. Power releases from the New Melones powerplant could cause fluctuations of up to 10 feet in Tulloch Reservoir, but the net effect would he dependent on how the irrigation districts operate the reservoir, which is not known at this time. Operation studies show that the water levels in Tulloch Reservoir will be higher with New Melones in operation, on the average, than the levels which currently exist.

(2) Comment: Recreational impact: Peak water releases from New Melones Powerplant which we understand u< ri ***. could create potentially hazardous currents in the portion of Tulloch Reservoir upstreoa from'th^ U'uyraes *lerry Bridge and further could cause the water surface elevation in Tulloch Reservoir to rise at a rate in excess of 7 inches per hour, both of which effects we believe would be detrimental to the recreational features of Tulloch Reservoir, which are presently enjoyed by thousands of people annually. The anticipated short-term fluctuations in water surface elevation would also increase the cost of Installing and maintaining boat docking and servicing facili­ ties on Tulloch Reservoir.

Response: The powerplant releases of 8,300 c.f.a. would occur; however, these flows are considerably less than the flows up to 60.000 c.f.s. which currently occur periodically, particularly during the rainflood season. Under existing conditions, snowmelt floodflows of 9.000 to 12,000 c.f.s. occur, often during a part of the recreation season. Although flows up to 10,500 c.f.s. (8,000 c.f.s. for flood control and 2,500 c.f.s. for irrigation) will now occur, they will not create a new situation with which the recreationists are unfamiliar. The short-term fluctuations in water surface elevations will probably increase maintenance costs of boat docking and servicing facilities as stated by the districts.

(3) Comment: The 10,000 to 20,000 acre-feet of storage space in Tulloch Reservoir that will be used by the United States for flood control and reregulation will reduce the head available for Tulloch Powerplant and will thereby prevent the Districts from releasing their full irrigation water supply through the powerplant. It will be neces­ sary to release a portion of the water through the spillway or bypass valves without the generation of power. Not only will this Increase the cost of operating and maintaining the spillway and bypass facilities, but it will also reduce the DlstffrtT1 r~"— tp*rr— flTlg A* Tulloch Powerplant by as_mich as 20 percent^ and may thereby prevent jili^UlUtll&TU 11 Urn iuiiilling their cflRCTAAtual obligations to deliver power to Pacific Gas and Electric Company.

Response: The possibility of reducing the irrigation districts' power generating capabilities at the Tulloch powerplant result­ ing from the storage space in Tulloch Reservoir that will be used by the United States ia operating New Melones Lake is fully recognized. Reim­ bursement or exchange in like kind is being negotiated between the Bureau and the irrigation districts in developing the water supply contract.

(A) Comment: We feel consideration should also be given to the impact of New Melones Project on Woodward Reservoir. Woodward Reser­ voir is owned by the South San Joaquin Irrigation District and the shore area is operated by Stanislaus County as a recreational facility presently providing in excess of 300,000 visitor days of recreational use per year. Woodward Reservoir is presently filled during the winter months by divert­ ing water that would otherwise be wasted down the Stanislaus River. It is kept full and evaporation and seepage losses are satisfied out of the South San Joaquin Irrigation District's share of the water supply avail­ able under the Districts' joint water rights. The Stanislaus County Parks and Recreation Department has determined that 20,000 acre-feet is the minimum storage in Woodward Reservoir that would support present recreational use. Under current proposals of the Bureau of Reclamation for furnishing water to the Oakdale and South San Joaquin Irrigation Districts out of New Melones Reservoir, the strict limitation on the quantity of water the Districts could divert would make it necessary for the South San Joaquin Irrigation District, in many years, to reduce the amount of water stored in Woodward Reservoir to a minimum level below 20,000 acre-feet in order to reduce evaporation and seepage losses. We therefore assert that the operation of New Melones project, as presently proposed, will significantly impair the tecreacTUlliU use uf W’judwaul "" Reservoir.

Response: Woodward Reservoir located about 5 miles north of Oakdale has a storage capacity of 35,000 acre-feet and is owned and operated by the South San Joaquin Irrigation District and is a part of that district's irrigation supply system. Stanislaus River water is diverted at Goodwin Dam and stored in Woodward Reservoir for subsequent use on lands north and west of Oakdale. At present the Bureau of Recla­ mation is negotiating with Oakdale and South San Joaquin Irrigation Districts for Irrigation services from New Melones Lake, and the desire of those concerned to eliminate drawdown of this multiple-purpose facility to produce increased recreation benefits is a part of the larger issue over the amount of irrigation service to be provided. The Bureau of Reclamation's proposal is to deliver water to the irrigation districts' canal intakes amounting to 572,000 acre-feet annually, with deficiencies in dry years (68). The irrigation districts believe this proposal does not provide the flexibility and potential which they now have with their current water rights and facilities. They have indicated that their present water rights exceed the amount allowed for them in the Bureau of Reclamation's proposal. The irrigation districts contend that the Bureau of Reclamation's proposal would require withdrawal of stored water in Woodward Reservoir to meet their irrigation demands. Indications are that 20,000 acre-feet or more of water would be required annually to maintain Woodward Reservoir at a higher level for recreation on the basis of post-operation of the reservoir. Relatively large seepage losses are occurring and probably would Increase with higher reservoir levels unless some economical method is found to reduce the losses. To retain higher reservoir levels during the recreational season would require some water to be released solely for this purpose. Water releases for fishery purposes cannot be routed through Woodward Reservoir and back to the river since it would bypass a large portion of the spawning area. The final effect on Woodward Reservoir cannot be evaluated until the present negotiations between the irrigation districts and the Bureau of Reclamation are completed and an agreement is reached on the contract providing water service or storage from New Melones in lieu of existing Melones Reservoir. With New Melones Lake, new water developed by the project will be available for purchase by the Irrigation district for stabilizing the level of Woodward Reservoir. The Bureau of Reclamation will report on this matter further in their environmental statement to be filed with the Council on Environmental Quality prior to operation of the project.

(5) Comment: The Draft Environmental Impact Statement devotes considerable attention of the matter of Whitewater boating. We seriously question the suitability of a reach of the Middle Fork Stanislaus River above Stanislaus Powerplant for mitigating the loss of the present Whitewater boating area. The average stream gradient above Stanislaus Powerplant is more than twice the average stream gradient below it, making that reach much more hazardous than the reach that will be inundated by New Melones Reservoir. In addition, we believe a substan­ tial flow of water would be required to support whltewater boating above Stanislaus Powerplant. Except for the normal spill period during the late spring and early summer, such water would have to be released from storage upstream and could not be used to generate power at Stanis­ laus Powerplant. Because of the tremendous value of that falling water for power generation purposes, we believe that the cost to the United States of making it available for whltewater boating would be prohibi­ tive. In addition to the cost of the stored water, other extra costs would be associated with the operation of Beardsley Dam, Beardsley Afterbay Dam and Sandbar Dam in regulating releases for that purpose.

Response: It has been determined that'the Middle Fork of the Stanislaus River is not suitable for mitigating loss of the whltewater reach.

(6) Comment: The Draft Environmental Impact Statement also refers to potential whltewater boating between Goodwin Dam and the Knights Ferry Bridge. We wish to point out that most of that particular reach of the Stanislaus River is bounded on both sides by canals of the Oakdale and South San Joaquin Irrigation Districts. Because of the Inherent hazards associated with these deep, swift-flowing canals, the Districts do not encourage public use of that reach of the river and are not willing to accept any liability associated with the provision of public access to the Stanislaus River in the vicinity of Goodwin Diver­ sion Dam.

Response: Should Whitewater boating be established on the Stanislaus River between Goodwin Dam and Knights Ferry Bridge, adequate measures to protect the irrigation districts' canals and the public would be included as part of the plan.

11. CITY OF MODESTO

(1) Comment: Dry Creek in Stanislaus County flows from the foothill area between New Melones and Don Pedro Reservoirs to the center of Modesto where it empties into Tuolumne River. City parks are being planned along Dry Creek for a distance of approximately five miles and along Tuolumne River for a distance of approximately seven miles. These two regional parks will also include a park area at the confluence of Dry Creek and Tuolumne River. We estimate that countless numbers of people will use these tree-shaded urban parks dally.

Dry Creek is highly polluted with dairy wastes at the present time, which are being removed with help from the State Water Resources Control Board, Stanislaus County, and the Agricultural Stabilization and Conserva­ tion Service. I understand the Corps also is interested in this program under provisions of the 1899 Refuse Act.

Response: The Corps of Engineers requires a permit for any discharges into Dry Creek that fall under the purview of the Refuse Act Program. To obtain a permit, dischargers are required to conform with established State and Federal water quality standards.

(2) Comment: Perhaps a small amount of New Melones water could be Introduced into the upper reaches of Dry Creek, either through facilities of the Oakdale Irrigation District or with a new conveyance. Such a flow would help convert Dry Creek into a beautiful waterway, particularly after the pollutants are removed as expected. The water would reach the Delta via the Tuolumne and San Joaquin Rivers.

Response: This appears to be a desirable use for some of the New Melones Lake conservation yield. The U. S. Bureau of Reclamation is the agency administering the conservation water for such purposes. (3) Comment: It has been brought to my attention that your division may recommend using New Melones water to improve water quality in the lower Stanislaus River, the San Joaquin River and the Delta, and we think that is a good idea. Ue also understand a flew in the lewer Stanislaus exceeding 600 cubic feet per second is not recommended for canoeing and other boating recreation, and hope you will consider that in your final decision.

Response: As stated in paragraph 30 of the EIS, up to 70,000 acre-feet per year will be utilized for water quality purposes in the Stanislaus and San Joaquin Rivers, in addition to the minimum releases for fish that is presented in table 14. As can be seen in table 8, flows will generally be below 600 cubic feet per second with project operation during the summer months.

12. ENVIRONMENTAL DEFENSE FUND

NOTE: The following comments are furnished by Mr. Gerald H. Meral, Environmental Defense Fund staff scientist. The first nusfcer appearing in parentheses after "Comment" refers to paragraphs in the Decenfcer 1971 Draft EIS, while the second nunfcer refers to the page.

(1) Comment: The Environmental Defense Fund's principal objection to the project is still the fact that it will be operated as a unit of the proposed East Side Division when that unit is authorized. The additional irrigation the East Side Division would provide is not now needed by the people of the United States, and would actually prove detrimental to the agricultural industry both in California and the Nation. We believe that the EIS does not explore adequately the possibility of operating the project as a water supply facility for the San Francisco Bay-Delta environment.

Response: Congressional authorization of the New Melones Lake project specifically provides that the project ". . . shall become an integral part of the Central Valley Project and be operated and main­ tained by the Secretary of the Interior. . ." Because of the legislation providing for integration of this project into the Interior Department's Central Valley Project (CVP), disposition and use of the water and power from the project is within the discretionary authority of the Secretary of Interior. Since the proposed East Side Division of the Central Valley Project has not been authorized for construction, its Impact on the environment will be evaluated prior to Congressional authorization, pursuant to Pt£>llc Law 91-190. The feasibility report for New Melones Lake, project document, House Document No. 453, 87th Congress, 2d Session, Indicated there were several potential service areas for the water to be made available by the New Melones project. Conveyance of water via the proposed East Side Division facilities was selected for purposes of computing benefits for the feasibility studies only, and does not restrict use of the water in other geographical areas of the CVP, including the Delta area. There is additional discussion in paragraphs 4 and 30. Specific operational alternatives will be fully addressed in the EIS to be prepared by the Bureau of Reclamation at a later date.

(2) Comment: A second objection is that alternatives are not really given fair consideration. The entire report*Is written under-the— . 'Supposixfon tnac the 'pro ject1 will continue to be built as presently plailRtiU. Ufliy scanty consideration is given to alternate poSiSlUle operat­ ing methods.

Response: All alternatives have been given consideration during project feasibility, plan formulation, and other studies. These alternatives, and variations of them, were reviewed and reconsidered during the preparation of the environmental statement. The effects of the alter­ natives are described in the environmental statement, and the statement considers the impact of each alternative, pursuant to PL 91-190 and the guidelines of the Council on Environmental Quality. Alternative operating methods have been given consideration both in formulation and review. To the extent such alternatives are feasible and applicable, options to use them will remain after construction. Specific operational alternatives will be described separately as mentioned in response to previous comment.

(3) Comment: Third, there are no guarantees even proposed that substantial mitigation will take place in the fields of Whitewater boating, downstream canoeing (the question of adequate flows for that part of the river is almost entirely ignored), fish and wildlife protec­ tion, and riparian habitat protection. Unless some sort of firm guaran­ tees can be given that the Corps will at least formally request Congress to consider some sort of mitigation other than what is now planned, the EIS can only be considered to be a detached study, with no real promise that any of the problems discussed will really be dealt with.

Response: Alternative plans and proposals for possible mitigation of Whitewater boating and downstream canoeing, as well as for fish and wildlife riparian habitat protection have been developed. Such plans have been discussed with environmental groups and were presented for consideration at a public meeting on 2 March 1972. The latest infor­ mation for these aspects is presented in paragraphs 10 and 27. No "firm guarantees" are promulgated as there is no legislation or other authority by which a Federal agency can issue a guarantee of performance. It has been determined that adequate legislative authority presently exists for the Corps of Engineers to implement one of the alternative plans for lower Stanislaus River below Goodwin Dam. These alternative plans were described and discussed at the public meeting held in Modesto on 2 March 1972. (4) Comment; The EIS should contain all of various studies described within it, Including those of the flora and fauna, whitewater boating, caves (NSS), fisheries, Kay and Meral, and others. Information from those studies has been added to this EIS since the draft EIS was prepared.

Response: The EIS is a summary of the direct and indirect environmental impacts of a water resources development project, and is not intended to be a compilation of all source and reference documents that were used in the analysis. Appropriate references have been made to such documents, references, and studies, where appropriate.

(5) Comment: A serious fault of the working paper, carried into the Draft EIS is the lack of substantiation of the various claims made in the report. There are literally hundreds of assumptions and factual statements made about every phase of the project without any references given or sources quoted. The EIS should be a scientifically correct study, and as such should follow the rules of scientific writingr As it is now written, it is only a collection of allegations.

Response: The information presented in the EIS is sub­ stantiated by references to source data.

(6) Comment: The problem of easements along the lower river is a very serious one. I understand that the Bureau of Sports Fisheries and Wildlife proposed that up to 3,400 acres be purchased by the Corps for riparian habitat protection. We concur, although not necessarily with that exact figure.

Response: Various alternatives for fish and wildlife habitat protection on the lower Stanislaus River are discussed in detail in paragraph 9 of the EIS.

(7) Comment: The EIS's statement that local control is the only practical method for protecting the riparian environment is false, as indicated by the figures on the destruction of the habitat in the last few years cited in the EIS.

Response: The statement concerning local control refers to avoiding adverse effects from secondary development on private lands, outside the new flood plain, following completion of the New Melones project. Since the Federal Government's authority applies only to Federal lands acquired for New Melones Lake and associated purposes, responsibility for control of development on adjacent lands is a function of local (non- Federal) governments. (8) Comment: The tables and figures in the EIS should be numbered and listed In the table of contents.

Response: The EIS has been revised as suggested.

(9) Comment: As was the problem In the working paper, the discussion is disjointed: almost every issue Is discussed in a number of different ways in the various sections. This is especially true of the discussion of the alternative uses of the project yield (irriga­ tion versus Delta protection), and whitewater boating. The CEQ guidelines could be followed while still making the report shorter and more readable.

Response: Although the EIS has been revised to improve the format, it is recognized that some topics are discussed in more than one place due to the inter-relationship of many factors. The format was developed to be responsive to the five specific ,joints described in Section 102(c) of Public Law 91-190 and other information required by the guide­ lines issued by the Council on Environmental Quality (CEQ).

(10) Comment: The EIS should be sent to the various political officials in the areas affected, including Congressmen Johnson, Sisk, McFall, Waldie, Mathias, Talcott, and perhaps the S.F. Bay Congressmen. Senators Tunney and Cranston should also receive the EIS. Since other local agencies are being consulted, so should the local Assemblymen and Senators.

Response: Since the EIS is made available to Congress pursuant to Section 204 of Public Law 91-224— The Environmental Quality Improvement Act of 1970, copies are not sent directly to individual members of Congress, unless requested. The EIS is furnished to representa­ tives of the State of California pursuant to guidelines developed by the State.

(11) Comment: We wish to call special attention to our comments on the allocation of water rights from the Stanislaus (EIS p. 5) and the earthquake hazard (EIS p. 43).

Response: See EDF comments and response numbered 21 and 31 below.

(12) Comment: With regard to mitigation for the whitewater boating section of the river, we note that the Corps has had little experience with this sort of problem. This is a new area generally, so we will be especially interested in how mitigation for this loss of a benefit will occur. Response: Details of mitigation plans and proposals for whltevater boating are discussed in paragraph 27.

(13) Comment: We once again raise the question of who will pay for removal of the dam once its use is at an end. Even though the reservoir will be less than one percent silted in, the dam itself presumably has a limited lifetime. If the project life period is now 100 years, what will happen after that? This entire question is neglected, except for a brief mention under "adverse environmental effects."

Response: To determine economic feasibility, a time period of 100-years is used as the basis for computing and comparing annual benefits and costs. Although the economic life is computed on a 100-year basis, with proper maintenance of facilities, the project can be functionally operated for a much longer period. Actual physical life of the dam will be in excess of 100 years. If it is determined that removal of the dam is necessary, it will be the responsibility of the Federal government to do so.

(14) Comment: We propose that the project be re-evaluated under the new Water Resources Council guidelines, including new interest rates, and new social, economic, and environmental consideration. This would give a better idea of what society now sees as the true value of the project. In addition, such a re-examination would make it possible to attempt to resolve the presently "unreconciled conflicts."

Response: The project has been evaluated on the basis of current Water Resources Council guidelines. New guidelines have been proposed, but have not yet been adopted.

(15) Comment: We object to the manner in which the coordina­ tion between the Bureau of Reclamation and the Corps of Engineers is being carried out. While the project is being built for the Bureau of Reclamation, the Corps is taking all of the responsibility of writing the Environmental Impact Statement. It thus becomes clear why there can be few or no guarantees about mitigation, ^tpr<> fhf 0*1 11 H ’Lfle responsibility in operating the project, Through conversations with the Bureau, we have learned that they still believe that the East Side Division is a viable project, and intend to press forward in Congress and elsewhere for its authorization. If this is the case, it is very unlikely that they are giving serious consideration to other alternatives. This means that all the work the Corps is doing on alternatives will probably be discarded by the Bureau, making the entire process of prepar­ ing the EIS somewhat futile. To correct this situation we suggest that the Bureau become more intimately involved in the planning process, and in the preparation of the EIS. For a start, the Bureau's comments on the Draft EIS should be immediately circulated to the other parties commenting on the EIS, so that their views will be more widely known. Second, the Bureau's evaluation of the need for water from the project in the East Side of the Valley and in the Delta should be included in the EIS. Finally, a statement of intent with respect to agreements the Corps makes with regard to operating the project is desirable. This would alleviate the Impression that the Corps is simply acting as a shield for the Bureau, deflecting any criticism of the project by dealing with the public, yet all the while stating that they do not have ultimate responsibility.

Response: The planning, design and construction of the project are the responsibilities of the Corps of Engineers. Close coordi­ nation has been, and will continue to be, maintained with the Bureau of Reclamation so that the views of the operating agency (Bureau) are taken into consideration. All project features are fully coordinated in advance with the Bureau of Reclamation and are incorporated into the project only if that agency includes it in the operational plans. At the public meeting in Modesto on 2 March 1972, the Assistant Regional Director of the USBR stated that all features of the project constructed by the Corps of Engineers would be functionally operated by USBR.

All comments received from other agencies on the Draft EIS are Included herein. The Bureau of Reclamation will evaluate environmental Issues associated with the East Side Division at the time their proposal for the East Side Division is submitted for authorization. Information on this aspect appropriate for the EIS on New Melones Lake is contained in paragraphs A and 30. Responsibility for operation of the completed project is clearly specified in the Flood Control Act of 1962, which states that this project will ". . . b e operated and maintained by the Secretary of the Interior. . ."

(16) Comment: Finally, since a final Environmental Impact Statement is not complete, we request that all work on the project cease, and that no further contracts be put out for bid or accepted until the final EIS has been on file with the CEQ for 30 days.

Response: The Corps of Engineers has no discretionary authority to refrain from acting in accordance with a number of specific statutes enacted by Congress and pursuant to continuing appropriations by Congress for prosecution of the work. However, in response to the spirit in which the legislation was developed, additional construction contracts for this project have been deferred pending completion of this EIS. (17) Comment: Title of EIS should be on "project", not on "Lake."

0 Response: The title, "New Melones Lake, Stanislaus River, California" is the official name of this project and refers to the project in its entirety.

(18) Comment: Since we know of no mailing before January 10, 1972, it should be dated no sooner than that.

Response: The draft EIS was dated December 1971 at the time it was authorized for release by the District Engineer. It was first transmitted to others for official review on 7 January 1972 follow­ ing final typing and reproduction.

(19) Comment: (3-4) It would be helpful to provide a sample expected schedule of releases for water quality. It is known when these releases would most likely be needed.

Response: A schedule of releases for water quality based on historical flow data, had the project been in operation during the period, has been included in table 13, paragraph 30.

(20) Comment: (5-4) This is a significant section. In the last paragraph, the statement of the authorizing act mentions "needs within that basin." Does the Corps take this to mean that the needs of Sacramento-San Joaquin Delta are included under the mentioned "needs?"

Response: The phrase "needs within that basin" refers to the Stanislaus River Basin, but also includes other areas within the counties through which the Stanislaus River flows. This statement does not refer to the Delta.

(21) Comment: (5-4) We would like to briefly discuss the Water Rights appropriation. First, the application (and permit) state that the powerplant would be completed on or before 1970. This is not the case.

The Water Rights were applied for (and granted to) the Bureau of Reclamation. The permit specifically points out that the water is to be used in the East Side Division of the Central Valley Project (p. 3 "USE": "Upon completion of the proposed East Side Division, the operation of the New Melones Dam will be integrated with the Central Valley Project"). Other information in the Water Rights application clearly indicate that the water is intended for use in the East Side Division. Response: Upon completion of construction, the New Melones Lake Project shall become an integral part of the Central Valley Project, pursuant to the authorizing legislation. The water rights application for storage of water for conservation purposes indicates that new water developed by the project is intended for use within a large area comprised essentially of the existing and potential future areas of service of the Central Valley Project within the southern half of the Central Valley. The reference in the application to the East Side Division indicates a possible jeans by which Stanislaus River water can be utilized within the Central Valley Project. A permit for the water rights for conserva­ tion purposes has not yet been granted.

(22) Comment: (9-10) There should be some definition of "extensive channelization."

Response: Extensive channelization includes widening, deepening, and sometimes straightening the channel, possible construction of new levees, and removal of all or part of the riparian habitat. This type of work will not be accomplished on the lower Stanislaus River.

(23) Comment: (9-11) This analysis of costs and benefits is inadequate. There should be at least some breakdown of what the costs and benefits are. In addition, the project should be examined in terms of the proposed new Water Resource Council guidelines on water projects. This would provide some perspective on how the project would fare if examined in light of the desires and needs of the United States in 1972.

Response: The EIS is a summary of all the factors con­ sidered in evaluating the environmental Impact of the proposed action. Detailed data on costs and benefits are not included, as they are avail­ able in other forms. Response concerning the Water Resource Council guide-. lines is contained in the response to Comment 14. * (24) Comment: (21-18) The estimate of 20,000 angler days in the river upstream of Melones Dam is now ten years old. Rising popu­ lation, as well as Increased popularity of river fishing would indicate that this figure should be increased to at least 30,000. In Meral's report on the Stanislaus River the figure used was 15,000 angler/days. Tills was an error.

Response: Updated angler day-use estimates are in this EIS.

(25) Comment: (21-18) The data on fishing below Goodwin Dam, and in Tulloch and Melones Reservoirs is similarly outdated. Response: Reference is made to the preceding comment and response. Fishing data was obtained from the Bureau of Sport Fisheries and Wildlife. Angler day-use in Tulloch and Melones Reservoirs has been updated. Significant increases in angler use on the lower Stanislaus River has been prevented by lack of public access and poor summer flows and low water quality.

(26) Comment: (22-20) The report mentioned (by Jones and Stokes) should be appended in its entirety. The discussion of endangered species is especially relevant.

Response: The Jones and Stokes report is summarized in the EIS and is available at the Sacramento District Office of the Corps of Engineers. See response to comment number A.

(27) Comment: (29-25) We repeat our question about refuse act permits for the various mines near the river, especially the asbestos mine. A discussion of the recent problems with some of these mines should be included.

Response: There is no evidence of a discharge from the Pacific Asbestos Company's mine requiring a permit under provisions of the 1899 Refuse Act. The only other known operating mine in the area is the Merck Chemical Division's marble quarry upstream from the project area. Discharges from this mine are about 100 gallons per day, and a permit application has been filed.

(28) Comment: (31-) It should be pointed out that the Knight's Ferry location is selected because of the proposed diversion of water from this point into the East Side Division. This was clearer in the working paper.

Response: The heading on table 8 in the Draft EIS is correct and clear since irrigation yield could be diverted from the Stanislaus River without the East Side Division Diversion Dam at Knights Ferry.

(29) Comment: (32-) There is a typographical error in the table headings which reads "five low months" instead of the previous "five lowest water years." The heading on the final table (p.. 32) should be "five highest water years."

Response: The heading "months" is correct. The figures for five lowest and five highest months were derived from the lowest and highest flow months of record irrespective of the year or years in which such months occurred. A typographical error which read "LOW" instead of "HIGH" in the lower one-third of that tabulation has been corrected. (30) Comment: (33-26) Included In this discussion should be the effect of a flood larger than the maximum one planned for. What will be the effect pn agriculture, business, and homes which locate on the flood plain expecting total flood control?

Response: The design flood for the New Melones Lake project is one with a very rare occurrence, having less than a one percent chance of occurring in any year. Should a flood larger in magnitude occur, downstream areas would experience flooding to a degree similar to that occurring under existing conditions. The effect on homes, agri­ culture and business in the flood plain would be that they would experi­ ence flood damages. Most flood control projects do not provide total flood protection. The degree of flood protection to be provided by the New Melones Lake project is considered adequate for the type of flood plain and hazard to life involved.

(31) Comment: (33-26) While there may be low probability of dam failure due to earthquake or other causes, the effect would be so devastating (particularly if the reservoir were full) that the impact should be discussed. How many deaths would be expected, and how much property damage would probably occur?

Response: The design of the New Melones Dam is based on criteria utilizing an impervious earthfill core and rockfill outer section. Dams of this type have withstood severe earthquakes with the epicenter located close to the dam, without appreciable damage. Accord­ ingly, the New Melones Dam is expected to be able to withstand earthquakes of the magnitude experienced and expected in the region. If the dam were to fail suddenly for any reason, and if the reservoir was full at the time, damages would be catastrophic and many deaths could be expected; however, there is no known rationale for determining such losses to any degree of accuracy.

(32) Comment: (33-26a) What are the alternative means of protecting the 235,000 acres from floods?

Response: There are no other reasonable alternative means of protecting the 235,000 acres along the San Joaquin River. Use of these lands could be limited by zoning but damages would still occur from flooding, such as erosion, inundation, and deposition of silt, gravels and debris.

(33) Comment: (34-26b) It should be made clear that all the power generated by the project would be utilized by the East Side Division, should it be constructed, and that this is the present inten­ tion of the Bureau of Reclamation (''Economic Analysis Appendix, East Side.Division, Central Valley Project, September, 1961" by USBR, Depart­ ment of Interior). The environmental impact of this increase in power generation should be discussed, in terms of what the power will be used for. In addition, there should be some discussion of the effect of new transmission lines.

Response: If the proposed East Side Division is constructed, it would require more power than will be produced by the New Melones Powerplant; however, the authorizing legislation for New Melones provides that up to 25 percent of the additional energy produced by the project shall be available to preference customers (public entities) in Tuolumne and Calaveras Counties. The remaining available power would become a part of the total Central Valley Project load and could be utilized for project facilities or commercial sales. The use and effect of new trans­ mission lines is included in paragraph 35.

(34) Comment: (35-26b) There should be some discussion on the effect of diverting another 325,000 AF of water from the Delta, especially the effect during the critical summer months, and the effect on flushing of the Bay during the winter months. In addition, more discussion is needed of what happens to the irrigation water once farmers are done with it: since it then becomes agricultural wastewater, it can have serious effects on water quality: this should be discussed both for the local area and for the ESD service area.

Response: Additional information and discussion has been added to paragraph 30 of the EIS concerning water quality. As indicated in table 8, with diversions of water from the Stanislaus River after completion of the New Melones project, flows during the summer months will be considerably higher than under existing conditions, particularly in dry years. Winter flushing flows will be reduced in the Bay and Delta.

The subject of irrigation return flows is discussed in response to comment 47.

(35) Comment: (35-26) The reader should be referred to page 91 which deals with the true value of new irrigation water, or that section should be incorporated into this one.

Response: References to divergent views discussed later in the EIS have been added, as suggested. Additional information regard­ ing irrigation benefits is discussed in paragraph 4.

(36) Comment: (36-27a) This section is inadequate. First, Mr. Kay's data for 1970 indicated that there were actually 9,000 visitor days due to professional rafting. He included 2,000 visitor days due to tourism in the river area before and after the raft trip, in addition to the 7,000 visitor days on the river itself. The total figure for 1971 should be shown, which was about 13,000 (final figure pending). The figure for fishing is from 1960 or so, and should not be cited as "(1970)." A current figure, as mentioned above must be around 30,000. The table should thus appear as follows:

Estimated Recreation Days Activity Annually (1971)

Commercial raft trips 13,000 Private rafting & kayaking 10,000 Fishing on river 30,000 Miscellaneous (gold mining) 15,000

68,000

Response: The 7,000 recreation day-use annually was used in the Draft EIS because it was not clear that the "2f,000 recreation days annually in added tourism" was attricuted to commercial raft trips. This has been clarified in table 10. Since the 13,000 recreational day-use annually for commercial rafting trips is not the final estimate, it is not used in table 10 although it is mentioned in paragraph 27. Recreation day-use annually for fishing on the river has been updated.

(37) Comment: Given the rate of increase of many of these activities, and the increased interest of the public in wilderness-oriented activities, it seems likely that the estimate of "60,000 recreation days annually by 1980" is far too low. A better estimate would be about 90.000 visitor days annually.

Response: Examination of the two source references indicates they are not based on detailed field surveys or cross-checked for duplica­ tion or other errors, as is the practice of the Corps of Engineers in conducting recreation use surveys. Without further data and a detailed substantiation of existing use and projections into the future, there is no evidence that use by 1980 in the 16-mile reach of river discussed would reach 90,000 recreation days of use annually. An annual use of 90.000 recreation days within this reach of narrow canyon would constitute serious overcrowding and would degrade and possibly destroy the wilderness experience visitors seek. Calculation of the optimal load resulting from such a level of use indicates there would be 900 persons on this reach on an average weekend day during the peak month of use, or more than 50 persons per mile. This appears to be excessive and beyond reasonable expectations. (38) Comment: There should be some substantiation of the estimates of reservoir use. This could include statistics on use from opening day to present on other reservoirs in the area, such as New Hogan. In addition, some measure of the predictive ability of the Corps and other agencies in this field should be shown, such as the estimates versus actual use of such reservoirs.

Response: The Corps of Engineers method for predicting recreation use is described in Technical Report No. 2, October 1969, entitled "Estimating Initial Reservoir Recreation Use." This report is available in the Sacramento District office, together with informa­ tion on its specific application to New Melones Lake. The methodology utilizes statistics on other reservoirs and has received wide distribu­ tion and acceptance among professional recreation planners. This method­ ology has been in use in the Sacramento District since 1965 and no project using this methodology has yet been completed. The method has, however, been tested on existing projects and gives reasonably accurate results.

(39) Comment: More discussion is required on the use of the lower river. How much use does it get now, and how much would it be increased or decreased under various alternative management plans? This section should include use with and without operation of the East Side Division.

Response: The information presented in paragraph 27 has been supplemented. No reliable information is available on the amount of use now occurring along the Lower Stanislaus River. Preliminary esti­ mates of increased use have also been included in paragraph 27, based on expectations associated with the various alternative concept plans for the lower Stanislaus. Considering the alternatives for increased flow in the lower river associated with the alternative concept plans, there is no significance to estimates of use with and without the proposed East Side Division.

(40) Comment: There is little or no discussion of the compara­ tive values of the two resources: wild river versus reservoir. The qualities of the resources are obviously not the same as discussed in many articles by Knetsch, Clawson, Leopold, and others. The new guide­ lines of the Water Resources Council point out that most reservoir oriented activities may be valued at $0.75 to $2.25 per visitor day, while more specialized (such as river oriented) activities are valued at from $3 to $9 per visitor day. Response: A discussion of comparative quality of river recreation and associated values and reservoir recreation and associated values has been added to paragraph 27. Basis for determining benefits is presented in paragraph 10. The new guidelines proposed by the Water Resources Council have not yet been approved for use by Federal agencies.

(41) Comment: (43-29) In this section the geology of the area, especially that of the damsite should be discussed. It is surpris­ ing that the probability of major earthquakes is not discussed. The Bostick Mountain Fault Zone (part of the Bear Mountain Fault) runs less than 1,000 feet downstream of the damsite, and the Melones Fault runs directly beneath the present Melones reservoir. In addition, this area was severely shaken by the Inyo earthquake of 26 March 1872, which would have read 8.25 on the Richter scale. The studies done by the Corps on the geology of the area should be cited in this section.

NOAA offered to study the effect of the dam on earthquakes in the area, but the Corps refused the offer. The study would have cost about $75,000, approximately 4 one-hundreths of one percent of the cost of the total project. Considering that the earthquake study was importaht to the preservation of the lives of tens of thousands of people, it is difficult to imagine that other more expensive mitigation facilities will be purchased and operated.

Response: Paragraph 22 of the statement has been revised to include additional geologic information at the damsite. No special mention of the Bostick Mountain Fault Zone or others is made because they are. not active faults in the sense that the Hayward, Calaveras, and other faults are active. Numerous geological publications are avail­ able which indicate there are dozens of inactive faults in the foothill area that have been inactive for a considerable period of geological time. There are no known records of a "severe shaking" of the Melones area during the March 1872 earthquake, or any other earthquake. It is known there were thousands of gold miners on the surface and underground in 1872 in the Mother Lode area but no known records of severe shocks have been found. There are numerous two-story buildings of unreinforced soft native brick in the foothills, built before 1850 that are undamaged. Although dozens of earthquake epicenters have been recorded in the last 30 years between latitudes 37 and 39 and longitudes 120 and 121, only 2 epicenters have been located within about 50 miles of the damsite. The dam is designed to resist a seismic force of O.lg with a reasonable safety factor. A seismic force of O.lg meets the earthquake intensity requirements for zone 3 of the International Conference of Building Officials, which is the maximum intensity zone in the State of California. The comment regarding the Corps' refusal to accept the NOAA proposal to study the effect of the dam on earthquakes in the area is misleading. The Corps of Engineers invited several agencies and university seismolo­ gists to submit concepts and proposals for seismic monitoring of the Melones area before, during, and after construction of New Melones Dam. The proposal submitted by the tf. S. Geological Survey's National Center for Earthquake Research was determined to be the most feasible and was accepted. An 8-station network for measuring seismic activity in the vicinity of the dam has been installed and will be continuously monitored by telemetry.

(42) Comment: (45-29a) There is insufficient explanation of damage to the caves. The NSS report should be included as an appendix. How much will the cave operators lose, and will they be reimbursed for this taking? In what ways will the inundated caves be damaged?

Response: No commercially operated caves will be inundated. Additional information on damage to caves to be inundated, including summary information from the National Speleological Society's report, has been added.

(43) Comment: (45-30a) The discussion in the working paper on irrigating the soils of the East Side Division service area was in some ways superior: it was more detailed.

Response: A discussion of soils in the Kern, Tulare, and Fresno Counties was not presented since it would not be pertinent as it is not known how much, if any, of the New Melones irrigation yield would be used in this area. Discussion of soil types, use and reuse of irrigation water, and irrigation return flow treatment and problems will be discussed in the EIS to be prepared by USBR on the distribution of New Melones water.

(44) Comment: While it cannot be denied that water quality is an authorized project purpose, it must be questioned whether this "toilet flushing" function of the reservoir can still be considered a benefit with regard to solving the pollution.problems of the Stanislaus. It would seem far more productive to propose methods by which the agri­ cultural return flows into the river could be treated. In addition, the Corps is indirectly responsible for many of the pollution problems on the Stanislaus, due to the total non-enforcement of the 1899 Refuse Act. Although Colonel Donovan has himself observed many violations of the Act (in a trip down the river), there has yet to be a permit granted for discharge into the river (to our knowledge), nor has there been any action to prosecute the many industries which discharge into the river.

Response: Existing water quality conditions are described in paragraph 16 and indicate generally poor conditions on the Lower Stanislaus and San Joaquin Rivers. Authorizing legislation for the project specifically directed that consideration be given . . t o the advisability of including storage for the regulation of streamflow for the purpose of downstream water quality control." Requiring treatment of agricultural return flows, where necessary to meet adopted standards, is the responsibility of the State water quality agencies.

The allegations concerning non-enforcement of the 1899 Refuse Act are not germane to the New Melones project.

(45) Comment: The discussion of the high winter flows into the San Francisco Bay is Inadequate. Indeed, it is implied that reduc­ tion of these flows would be a project benefit (30b). The USGS circular 637-A, B clearly implies that the high winter flows in the Bay are beneficial for flushing. While some augmentation for the summer period in the Delta is desirable, the main problem at that time is salinity intrusion and not pollution.

Response: The USGS circular 637-A, B describes seasonal salinity changes in the south bay. It clearly shows that as flows decrease towards their low point in the summer, salinity builds up to a high point in the south bay. To the degree that summer flows of suitable quality are increased, salinity buildup will be decreased. However, flows through the south bay consist mostly of water. Flows from the San Joaquin River under planned project conditions will have only a minor effect in this area. In recent years, Sacramento River flows have been regulated to effectively control salt water intrusion in the Delta.

The impact of reregulated flows due to the New Melones Lake project would be primarily on the Stanislaus and San Joaquin Rivers. The main problems in the San Joaquin River are high total dissolved solids (TDS) and low dissolved oxygen. It is a project purpose to control TDS to 500 ppm in the San Joaquin River at Vernalis. It is also a project purpose to control dissolved oxygen levels in the Stanislaus River to at least 5 ppm (indications are that this standard will be revised upward). It is therefore believed that reregulated flows will have a net beneficial impact over existing conditions.

(46) Comment: To what extent is there presently an anaerobic layer in Melones Reservoir? If the anaerobic layer is greatly increased, is there a significantly increased danger from methylation of mercury or other dangerous chemicals?

Response: There is no reliable field data available regarding the degree of stratification at Melones Reservoir. Based on data available from other large lakes, New Melones Lake can be expected to become stratified and will have a larger hypolimnion and longer retention time than the existing lake. To this extent, the total amount of certain materials that could be made soluble would increase. Investigations by geologists indicate that there are no significant heavy metal deposits in the project area that could be modified by anaerobic actions to dangerous concentrations.

(47) Comment: There should be some discussion of the effect of - occasional very high floodflows. These prevent intrusion of willows on the riverbed, carry away debris which can accumulate on the banks, etc.

Response: The suggested information is included in paragraphs 31 and 33.

(43) Comment: A discussion is needed of exactly when the water would have to be released for water quality under present conditions to meet the D.O. criteria listed. Is the 70,000 AF/yr presently allowed sufficient? Under present design, can the D.O. criteria be met with releases from the hypolimnion? Will the special works discussed be required, and when will the studies to determine this be completed? The Final EIS should not be released until they are.

Response: Water quality releases will be made during those periods needed to achieve the established water quality criteria. Predicted releases, based on historical flow records, are shown in table 13, paragraph 30. The need for such releases is greatest during the late summer months of the year. The amount of up to 70,000 acre-feet per year will be sufficient to satisfy the water quality objectives in 10 out of 11 years until the year 2075. Releases will meet the D.O. criteria; if necessary, hypolimnion water will be aerated. Cost estimates for aeration of Tulloch Lake indicate that an installation costing about $20,000 would accomplish this when and if needed. Water released to the lower Stanislaus will flow over Goodwin Dam, which is expected to further increase the D.O. to the criteria cited by the Bureau of Sport Fisheries and Wildlife.

(49) Comment: The discussion of the effects of irrigation on water quality is insufficient. To my knowledge the San Luis Drain is not presently under construction. The areas of potential irrigation must be pinpointed and carefully examined. The general statements about soil alkalinity could apply anywhere. Even so, it is clear that under present conditions in most areas there will be an overall detriment to water quality if the 325,000 AF of v/ater are used for irrigation, insofar as they irrigate new lands, or more intensively irrigate present agricul­ tural lands. Response: Fifteen miles of the San Luis Drain were completed in January of 1970 and a contract was awarded in July 1970 for construction of an additional 25.7 miles of the drain. Discussion of the service areas for the irrigation yield is contained in paragraph A. The impact of irrigation return flows presented in paragraph 30 has been supplemented.

(50) Comment: As is so often the case, a flat statement is made about an alteration in "natural waste assimilation capacity." Not only are no figures for this given at all, but neither is the direction of the change! This clearly means that the capacity will be reduced.

Response: The results of the change in waste assimilation capacity are included in the discussion of beneficial and detrimental aspects of the project on water quality in paragraph 30. The direction of the change has been added to the discussion. Quantification of the change would be speculative and would be dependent upon the degree of control and enforcement by the State water quality control agencies.

(51) Comment: There should be an especially detailed discus­ sion of the problem of waste water return which would enter the Stanislaus and the San Joaquin in the Vernalis area. If these are significant, the water quality benefits claimed by the project might be impossible to achieve.

Response: Based on the information received from the Public Health Service to establish the need for water quality control in the New Melones Lake project (reference 10), waste water returns will be offset by release of water from New Melones. Additional information from the PHS report has been added to table 13, paragraph 30.

(52) Comment: (57) Is it implied that roads are an improvement? This is a value judgement, and not appropriate in this context.

Response: Although the words "improve" and "improvements" are terms in general usage denoting various kinds of construction includ­ ing roads, the words "develop" and'developments" have been substituted.

(53) Comment: (A7, A9) There seems to be a conflict between the statements on page A7 and A9 about the effect of aneroblc and other conditions on the downstream (and Tulloch) fisheries and water quality. Is it or is it not now known whether there will be an effect?

Response: The general effect of hypolimnial discharges is known and there does not appear to be a conflict between the statements on pages A7 and A9 of the Draft EIS. It is known that hypolimnial discharges will be in the low temperature range, will be relatively low in dissolved oxygen and will contain a higher concentration of dissolved materials. Although the exact quantity of these parameters cannot be predicted for such a dynamic system, the range can be approximated by comparable conditions in other reservoirs. On this basis, quality of water stored in New ilelones and Tulloch Reservoirs will not adversely affect the beneficial uses of the water, including the fishery.

(54) Comment: (48) The PHS statement is now seven years old. EPA's comments on the validity of using reservoirs to clean up stream pollution should be included in the final statement. We believe that in most cases (including this one) man-made pollution should be cleaned up at the source, not diluted.

Response: The water quality releases are not intended to be a substitute for treating waste at the source but rather a supple­ mental solution since means to fully treat all wastes, including irriga­ tion return water, are not available. EPA's comments on the draft environmental impact statement are attached to this final statement.

(55) Comment: (50) What is the basis for saying that materials which enter the water under anaerobic conditions will leave the water under aerobic conditions? Will they leave via the biota to some extent?

Response: Commonly, materials made soluble under anaerobic conditions precipitate under aerobic conditions with the degree of aera­ tion being a factor in the rate of oxidation (or reduction) reaction. Since many of the dissolved materials are necessary for aquatic organisms, some will be removed biologically.

Also, bio-accumulation of some materials will occur and will be most pronounced at the higher trophic levels of the food chain. This is a natural phenomenon, and observations at existing reservoirs in the area indicate that this will not likely be a problem.

(56) Comment: (50) Obviously,one of the ways which future development could be controlled would be through purchase of easements along the lower river, and by extending the take line to prevent construc­ tion of hemes within the reservoir area. This latter method is being used by the Bureau of Reclamation at Auburn Reservoir.

Response: Since the river basin is quite large and con­ siderable future development could occur that would contribute to waste loading, project land controls could have only insignificant impact on the total area. Control of development in the entire basin is the function and responsibility of Stanislaus, Tuolumne, San Joaquin, and Calaveras Counties. The suggestions as to land acquisition as a part of the project to control Influences within the Immediate project area are not in accord­ ance with existing policy but are being studied to determine if a waiver of policy or special authorization should be recommended for this purpose.

(57) Comment: (49) Proof of the statement that inundating new areas will not have fin adverse effect on water quality is required. Occasional rain erosion is not comparable to inundationf especially con­ sidering the difference in oxygen conditions.

Response: The information presented in paragraph 30 is considered adequate to indicate that water quality conditions in existing reservoirs present no major problems of this kind.

(58) Comment: (50) No definitive statement is made that there will be no problem with supersaturation of nitrogen, nor is evidence offered.

Response: There are no known problems at California reser­ voirs associated with supersaturation of nitrogen. Problems have occurred at dams on the Columbia River under certain circumstances, but the condi­ tions are dissimilar to the Stanislaus River and New Melones Dam.

(59) Comment: (58-31b) This discussion is inadequate. There is no evidence at all presented here that there will not be significant harm to the spawning gravels. But surely there must be some evidence from rivers about what happens under such conditions.

Response: Mitigation and enhancement measures to be taken, as discussed in paragraphs 9 and 31, will provide protection to the spawning gravels.

(60) Comment: (59-31c) It is good to hear that planning is going on. However, to proceed with a project while plans are still in such a preliminary stage is contrary to sound planning and an invitation to disaster. If the project is completed before the plans are carried out, the Corps will leave the field, and the Bureau of Reclamation, operator of the disastrous Lake Berryessa, will become manager of the project. The Corps will thus be relieved of all its obligations in the field of management.

Response: All plans for project features will be completed and approved actions will be implemented prior to completion of the project and transfer of responsibility to the Bureau of Reclamation for operation and maintenance. The Corps of Engineers will retain responsi­ bility for maintenance of the project features in the downstream area below Goodwin Dam. (61) Comment: (59) It is my impression that the Fish and Wildlife Service has asked for purchase of about 3,200 acres above the reservoir, and about 3,400 acres along the flood channel. This would provide a strip from 200 to 500 feet wide on both banks all the way down the lower river, and would probably be adequate in most places. The area along the flood channel is vital*not only for wildlife habitat, but also for aesthetic purposes. This area will of course be especially- endangered by agricultural encroachment when flood protection is guaranteed.

Response: The recommendations of the Bureau of Sport Fisheries and Wildlife include lands for wildlife at the reservoir and downstream from Goodwin Dam. As discussed in paragraph 3, lands will be acquired for wildlife at the reservoir. Corps of Engineer plans for the downstream lands are proceeding on a schedule commensurate with the other aspects of the project and are discussed in paragraph 9.

(62) Comment: In addition, for any downstream angling benefits to occur, more public access will be necessary. It is stated that the public can only gain access to the river along 10% of its length. This two to four miles will obviously not be sufficient to permit the benefits described, nor will it be possible to protect spawning gravels.

Response: As discussed in paragraph 9, plans are being developed to protect the spawning gravels and to provide additional public access to the river, coordinating with the Federal and State fish and wildlife agencies, local governmental agencies, landowners affected, and others.

(63) Comment: (51) There is insufficient discussion of the impact of second home and commercial development around the reservoir. The effects on water quality could be notable. Some discussion of similar problems at other reservoirs would be appropriate.

Response: Additional discussion of secondary impact has been added, in paragraphs 24, 25 and 32.

(64) Comment: (52) While it may be quite late, it is appropriate to ask whether a Refuse Act permit has been issued. Issuing the permit to the Corps would permit EPA to comment more directly on the dam construc­ tion process.

Response: The Secretary of the Army administers the Refuse Act, under specific delegation of authority from the Congress. The Congress has enacted legislation directing the Secretary of the Army to construct the New Melones project. Accordingly, there is no requirement existing for the Secretary of the Army to issue a Refuse Act permit to his own organization. The Refuse Act states . . that nothing herein contained shall extend to, apply to, or prohibit the operations in con­ nection with the improvement of navigable waters or construction of public works, considered necessary and proper by the United States officers supervising such improvements or public works." There are no. restrictions or limitations on the comments from EPA.

(65) Comment: (52-31a) Obviously a wild river fishing experience will be lost. How is this compared to the increasingly common reservoir fishing experience?

Response; Areas will still be available for river fishing. Converting 16 miles of river fishery to a lake fishery is one of the project trade-offs; in addition, the establishment of a trout fishery downstream will result from construction of the project. It is significant to note that fishing throughout California is increasing at a rapid rate. Existing stream fisheries cannot sustain this increasing demand even with stocking programs. Additional opportunities are needed and the fishery potential of large lakes is recognized as a significant means to satisfy the need for fishing opportunities.

(66) Comment: (52-31a) What sort of fish can be expected in the warm water fishery?

Response: The resident fisheries are described in para­ graph 18. In addition to these species, the California Department of Fish and Game may introduce species such as striped bass to more effect­ ively utilize the reservoir resources for the production of game fish.

(67) Comment: (50-31a) The objectives for the downstream fishery should be made much more clear. What was the condition of the stream before man intruded with either dams or agriculture? Is it the goal of the Corps to regain those conditions? Or does the Corps intend to go beyond them, to increase the number of fish which use the river, or to change the species composition? Just because present conditions are deplorable, it is not clear that it is necessary to construct a giant dam to improve them. What would wastewater treatment accomplish, accompanied with altering the release regime from Tulloch, or perhaps accompanied by a smaller Melones or enlarged Tulloch?

Response: The objectives for the downstream fishery are presented in paragraph 31. The condition of the Stanislaus River in its pristine state is unknown and not relevant to the impact of the New Melones project on existing conditions. It is not the goal of the Corps of Engineers to restore conditions that existed before man's occupation of the basin. Authorizing legislation for the project requires measures be t^ken ". . . t o insure the preservation and propagation of fish and wildlife in the New Melones project." The recommendations and advice of the Federal and State fish and wildlife agencies are being used in accomplishing this. Treatment of wastes from local sources is not within the scope of the New Melones project, nor is it a viable alternative to the principal purposes of the project.

(68) Comment: (54-31a) "Unacceptable to fish" implies certain species under certain conditions. More detail is needed. Were conditions before man arrived on the scene "unacceptable?"

Response: As used, the term "unacceptable" applies to temperatures outside the temperature range specified by the Bureau of Sport Fisheries and Wildlife as acceptable for specified game fish in the Stanislaus River. Since years of low stream flow and undesirable water temperatures undoubtedly occurred before man's arrival it can be assumed that conditions were at times unacceptable for fish.

(69) Comment: (54, 55) How frequently would specified tempera­ ture ranges have been exceeded if there had not been an historic drought period: there should be a number following each number in the table marked with an asterisk which shows the number of days which occurred in the historic dry years.

Response: All of the occasions marked by asterisks in table 14 would have occurred during the historical drought period. The specified temperature range would never have been exceeded if there had not been an historic drought period; however, to ignore the historical records would not be a realistic consideration of the probable conditions that could occur in the future. The study is based on monthly values; daily results are not available.

(70) Comment: (56-31b) There will be little or no free-flowing river between Knight's Ferry and Goodwin Dam if the Knight's Ferry Reser­ voir is built. This would wipe out most of the proposed trout fishery.

Response: The California Department of Fish and Game's report (8) evaluating the impact of the New Melones project mentions the establishment of the trout fishery downstream of a potential Knights Ferry Diversion Dam. Goodwin Dam was used in the analysis as it is an existing structure; the proposed Knights Ferry Diversion Dam has not been authorized and its construction is not assured. The minimum guaranteed flows in the Stanislaus River for fish would be instrumental in sustaining the trout fishery.

(71) Comment: (62-32b) It is deceptive to list a supposed benefit in one place (for irrigation) and not list any of the costs either here or elsewhere. A discussion listing all costs and benefits should be given all in one place. Response: The dollar benefit description for irrigation has been replaced with a narrative description similar to the other benefits and detriments described in that section.

(72) Comment: (63-32c) This is incorrect. The only practical method of avoiding adverse effects outside the flood limits is direct acquisition of some of the riparian habitat, along with local control. To the extent that adverse impact is expected, acquisition should take place, along with speedy public notice to the citizens of the counties.

Response: As explained in response to comments number 7 and 56, the reference is to local government planning and zoning efforts for avoiding adverse effects of secondary development outside the lands to be controlled by the Federal Government in connection with the New Melones project.

(73) Comment: (61, 63-32) There should be some estimate of the additional costs of the project, such as increased policing, the cost to the public of removal of public lands, and so on. No project costs are allocated to the removal of public lands in the various reports to Congress. Is the land worthless?

Response: Law enforcement is primarily a local responsi­ bility and is not a function of the Federal cost of the project. While the cost of such enforcement may be an added burden on the local government, it is essentially a transfer of costs from elsewhere and not a net national economic cost. The statement regarding costs of removal of public lands is Incorrect. The report which was the basis for authoriza­ tion of the project includes, as part of the project economic costs, the estimated value of Federally-owned lands. This cost is included in the confutation of the cost-benefit ratio. The only costs not shown are the administrative costs of the agency transferring the land, which are nominal. Administrative costs for acquisition of private lands are included as a project cost.

(74) Comment: (57) Paragraph 26, not 28, is devoted to hydrology.

Response: Correction has been made.

(75) Comment: (64-32) What is the exact status of the Stanislaus River Designated Floodway? What will be required for the Reclamation Board to approve it?

Response: The California Reclamation Board has withheld action on designating the Stanislaus River floodway until New Melones Dam is nearer completion. The ultimate authority to approve a designated floodway rests with the Reclamation Board as a matter of State law. Coordination with other agencies, including the Corps of Engineers, and the results of public hearings are inportant factors in the Board's deliberations.

(76) Comment: (64, 67-33) The whole discussion of wildlife is almost esoteric. There is little mention of actual species, and no estimates of populations given. A wide variety of alternatives are named while no assurances are given that any will actually be Implemented. The only thing obvious from the discussion is that there will be a major loss of wildlife habitat, especially of riparian habitat, with almost no mitigation except in one area of less than 2,200 acres. There is now almost no guarantee of any mitigation of loss of wildlife.

Response: Paragraph 20 discusses wildlife in the environ­ mental setting without the project; supplemental data has been added. Response to Environmental Defense Fund's Comment 3 discusses the status of alternatives presented for wildlife mitigation; details of Corps of Engineers action for implementing the downstream mitigation and enhancement plans are presented in paragraph 9.

(77) Comment: Especially objectionable in the discussion is the mention of the "edge effect," not widely known from fluctuating reservoirs, the proposed "chemical treatment" of chaparral areas, and the statement that "grassland is not a limiting factor due to its abundance." The discussion is turgid and unclear.

Response: The edge effect statement has been affirmed and the source (California Department of Fish and Game) is referenced. Chemical treatment of chaparral is one of sever;! methods of managing wildlife areas routinely used by the California Department of Fish and Game. The phrase, "grassland is not a limiting factor due to its abun­ dance," has been deleted.

(78) Comment: (68-34a) The figure of 138 million dollars is deceptive. The total project cost could then be presumed to be 158 million, but it is now really 181 million (page 9). It might also be appropriate to predict the actual expected cost given the current rate of appropriation.

Response: The statement has been revised in paragraph 11 to clarify the difference in the quoted construction costs and the total project cost. With regard to the comment for predicting the actual expected project cost given the current rate of appropriation, it should be noted that the annual appropriation of funds normally vary during the overall construction period to facilitate the most economical rate of construction. Increases in estimated project costs and benefits due to inflation are reflected in the annual report to Congress when requesting appropriations of funds required to continue construction.

(79) Comment: All this mitigation of the borrow areas sounds good, but I am unfamiliar with any other examples where it has taken place. If it is initially unsuccessful, how long will the Corps keep trying to "revegetate" the area?

Response: Restoration of borrow areas has not been tried extensively in this region but the California Division of Highways has- had considerable success in restoring cut slopes by various combina­ tions of reseeding, replacing topsoil and hydromulching. Revegetation measures will leave islands of existing vegetation within the borrow areas which would constitute a perpetual natural seed source for restora­ tion of the area in addition to direct seedings. If initial efforts were to be partially unsuccessful for some reason, measures will be taken to replace and restore the unsuccessful portions.

(80) Comment: (71, 72-35) The vertical drawdown is of interest, but of more importance is the extent of exposed area during the average recreation season and at other times. A vertical drawdown of 260 feet below the clearing line would presumably expose thousands of acres of reservoir bottom: how many? Are these the "spectacular views" referred to on page 72?

Response: The amounts of area exposed,corresponding to several of the figures of vertical exposure presented,have been added to paragraph 35. Information concerning the views is discussed in the following response.

(81) Comment: (72-35) There seems to be a conflict between the "spectacular views" and the "unattractive drawdown zone."

Response: As stated, the large body of water will provide attractive views when full or nearly full. When the reservoir is at lower lewis, the exposed zone of fluctuation is considered unattractive to many, although measures will be taken to ameliorate this,as described in paragraph 35c. (82) Comment: (76-40) This can only be called "hearsay."

Response: Clarifying language has been added to paragraph 40. The information presented is a summary of the actions taken to mitigate wildlife habitat that will be adversely affected by the project. Such actions will be Implemented in close coordination with the Federal and State fish and wildlife agencies.

(83) Comment: (77-41) If this project were not so far along, this paragraph could only be described as shocking. It is completely inadequate if there is to be any serious consideration of real alternatives. Clearly there are more alternatives than just building the presently authorized reservoir at alternative sites. What about a 900,000 AF reservoir at the Tulloch site? It would inundate none of the river upstream of the present Melones reservoir, but still could undoubtedly provide most of the water quality, fish and wildlife, recreation and flood control benefits of the much larger New Melones Project. The main loss would be the Irrigation benefits and hydroelectric benefits of the larger reservoir. .But since it is likely that the water is not needed for irrigation, this is no real loss. I find it amazing that after much correspondence and many conversations with the Corps— including Colonel Donovan and General Camm— no mention of the smaller raised Tulloch is made.

Response: Discussion of an enlarged Tulloch Dam has been included. To be considered as an acceptable alternative, any plan must have a favorable benefit-cost ratio. On the basis of such criteria, the number of viable alternatives is reduced to only those that can reasonably satisfy the needs that will be satisfied by the approved project or whose deficiencies are acceptable trade-offs. In addition, the alternative of abandoning the project is considered. The need for conservation yield is presented in paragraph 4.

(84) Comment: I know of no investigation of the possibility of a reservoir upstream of Camp Nine. Contrary to the statement made, the only part of the watershed which would not be controlled would be the South Fork of the Stanislaus.

Response: There have been several studies made of the possibility of reservoirs being constructed upstream of Camp Nine (Stan­ islaus Powerhouse). One of the most recent studies is that conducted by the Stanislaus River Basin Group, composed of Calaveras County Water District, Tuolumne County Water District No. 2, Oakdale Irrigation District, and South San Joaquin Irrigation District, and published in a report dated October 1961. This report was considered by the Board of Engineers for Rivers and Harbors and the Chief of Engineers prior to their recommendation to Congress for construction of the New Malones Lake Project in lieu of the local development. A dam and reservoir constructed upstream of the Stanislaus Powerhouse would not control the same amount of watershed of the main Stanislaus River as New Melones Dam, nor would it control the South Fork of the Stanislaus River.

(85) Comment: (79-41c) The exact cost of inundating the Stanislaus Powerhouse at Camp Nine is of interest, since if any water is to be purchased from PG&E for whitewater mitigation, it will diminish the value of this powerhouse. Also, typical misplaced economic priori­ ties are shown again here: powerhouses can stop a reservoir, but a wild river cannot.

Response: Any negotiations for water to bypass the Stanislaus Powerplant to improve the boatabillty of the river would consider the replacement of power from New Melones for that lost at the Stanislaus Powerplant. The reduction in power production would diminish the value of the Stanislaus Powerplant, but such reduction in value would not equal the total economic loss of this powerplant should it be purchased and taken out of production.

(86) Comment: (80-43b) The real "need" for the reservoir is revealed in this statement. There is no reason the agricultural lands cannot be managed through a flood plain management plan. Some of the world's most productive agricultural areas survive in uncontrolled flood plains, as the EIS later points out. Much of their fertility comes from periodic flooding. In the Central Valley man has replaced this periodic nourishment of the soil with artificial fertilizers, and is paying for it through rising levels of nitrates in ground and surface waters.

Response: This comment raises the philosophical issue of whether man's development should be located in flood plains, and becomes a social and political decision rather than a technical issue. It is noted that development is already located in the flood plain and existing reservoirs on the Stanislaus River trap much of the sediments and nutrients. Intensive farm practices cannot be successfully and economically conducted in an unprotected flood plain.

(87) Comment: (81-44) 1.6 million acre-feet in addition to what amount? In what way would releases from New Melones be used to assist in meeting increased flow requirement into the Delta. This section, which presents a viable alternative to the project as presently proposed, should be greatly expanded. A management plan for letting all the water from the project not used in the local area Into the Delta throughout the year should be fully and adequately explored.

Response; Net flow requirements have been added In paragraph 44. The remainder of this comment Is responded to in Comment 3.

(88) Comment: (82-45) The "planned protection" of the riparian habitat is continually referred to, but is nowhere spelled out in any detail. At the moment, it seems most likely that the "ultimate destruc­ tion" will occur unimpeded by Corps action. The construction of new homes, referred to here and elsewhere, should be substantiated by refer­ ence to areas near other reservoirs. The activity (or lack of it) near Don Pedro, may give some indication of the desirability of such locations.

Response: The details of the plans for protection for fish and wildlife in the downstream area are discussed in paragraph 9. Information about new home construction relates to secondary impact and is discussed in paragraphs 24 and 32.

(89) Comment: (89-51) The device of using the category of "unreconciled conflicts" to contain problems which won't otherwise go away is unsatisfactory. One of the purposes of preparing an environmental impact statement is to try to resolve conflicts by finding alternatives which can satisfy as many of the goals of society as possible. Clearly the entire impact statement is written with one goal in mind: the con­ struction of the New Melones project as presently planned and authorized, with as little expenditure as possible on such problems as Whitewater boating, caves, riparian habitat, wildlife, fisheries, and so on. Therefore, there has been no real consideration of alternatives, especially those which might cost more.

Response: Extensive attempts are made to reconcile areas of disagreement or conflict. It is recognized that in a multiple-purpose plan not all interests and functions can be optimized. Where agreement cannot be reached, thorough discussion of such problems is presented in the section of the EIS titled "Unresolved Conflicts." All aspects of each problem are presented, together with a concise and objective analysis of the issues. The remainder of this comment has been answered in previous responses.

(90) Comment: (90-51) It is not true that water from the Stanislaus (from New Melones or any other project) to the amount of exactly 325,000 AF is required either for irrigation or for improving Delta water quality. Nothing in these comments, or in those by any other agency or organization ve know of can be taken to imply the above statement. There la no evidence for the statement. It is only another indication that the Corps intends to build exactly this project, and is totally unwilling to consider alternatives.

Response: The statement that "the amount of exactly 325,000 acre-feet is required either for irrigation or for improving the Delta water quality" was not contained in the Draft EIS. The statement was that ". • • the additional water supply of 325,000 acre-feet annually will be needed. . •" The amounts of water required for either Irrigation or for improving Delta water quality will greatly exceed the additional water to be provided by New Melones project. The size of New Melones Lake (and corresponding average annual conservation yield) is based on'an incremental economic justification for the 2,400,000 acre-foot reservoir to supply that yield. It is recognized that this yield does not represent the upper limit of new water needed for the area, but is the upper limit that can be economically justified on an incre­ mental basis from New Melones Lake.

(91) Comment: (91-51) The actual water rights should be mentlone in this section; as stated earlier, they are allocated to the East Side Division.

Response: The Bureau of Reclamation is in the process of obtaining the necessary water rights for the New Melones Lake Project. The EIS has been expanded to include this suggested information.

13. SIERRA CLUB (EXECUTIVE DIRECTOR)

(1) Comment: In my letter last July I urged that a thorough, factual and objective examination of the reasonable alternatives for meeting legitimate water and flood control needs be made. The present Draft Statement does not accomplish this. It is clear from the Statement that the Corps is committed to the project as it is presently designed, and that no real consideration is being given to alternatives, such as no project, an altered project, or a project in another area. We urge you to give much more serious consideration to these alternatives.

Response: All the alternatives mentioned in this comment have been considered and are included in paragraphs 41, 42 and 43. The reason that it may appear that the Corps is committed to the project, as presented in Section 1 - Project Description, is that this is the most viable alternative to meet the multiple-purpose functions of flood protection, water quality control, municipal and irrigation water Bupply* recreation, fish and wildlife and other beneficial purposes for which the project was authorized by Congress. (2) Comment; Decision 1379 of the State Water Resources Control Board, If It stands, will require large amounts of water for water quality In the Sacramento-San Joaquin Rivers Delta. If the East Side Canal is built, more dams will have to be constructed, probably on California's north coast, to satisfy this demand. Without East Side, New Melones water could be used in partial satisfaction of this requirement, and in response to New Melones authorizing language providing priority uses of water for the Stanislaus River Basin. We feel that the Corps should take a stand on the relative merits of the East Side Division versus the needs of the Delta. Our view is that the East Side Division should not be authorized, and that the water from the Stanislaus should be allowed to flow into the Delta.

Response: As noted in response to EDF comment 1 and other comments, the operation of New Melones Lake Project will be integrated into the operation of the Central Valley Project by the Bureau of Reclamation. The East Side Division is not authorized for construction. If and when authorization is proposed, the Department of the Army will be afforded opportunity to comment on the specific proposal.

(3) Comment: It should be very clear in the Environmental Impact Statement that the prime cause of environmental concern about the New Melones project is the proposed use of the water in the East Side Division. There is a growing body of evidence which indicates that there is already an overproduction of agricultural crops in California, and that the State Water Project will only aggravate this condition. The East Side Division (as supplied by the New Melones project) might deal a final blow to California's agricultural economy.

Response: (See response to EDF comment 1.) USBR projections indicate that the New Melones conservation yield will provide only a fraction of the water needed for irrigation, water quality and municipal water supply needed within the area that could be served by an East Side Division of the Central Valley Project.

(4) Comment: The New Melones project, if constructed at all, should only be of a size which would accomplish the benefits of flood control, fisheries, and water quality. These benefits could largely be met by a reservoir with a capacity of about half a million acre-feet. Or Tulloch Reservoir could be replaced with a reservoir with a capacity of about a million acre-feet. A reservoir of this size could also provide water for Delta quality. This impact statement does not consider these alternatives.

Response: The EIS has been expanded to include the con­ siderations given to these alternatives. (5) Comment: While some mitigation for the upper river (from Camp Nine to Parrott's Ferry) is discussed, there is no indication that any mitigation will actually take place, nor is there any estimate of the cost of such mitigation. Would the Corps purchase water from PG&E on the Stanislaus or any other river? How much would additional access roads or other facilities cost on the Stanislaus above Camp Nine? Has the Forest Service been consulted regarding new roads in the National Forest?

Proposals for replacing the whltewater recreation area of the Stanislaus are incomplete and most unsatisfactory as they now stand. The Sierra Club cannot accept either your environmental Impact statement or your statement at subsequent public meetings in this regard. It is apparent that mitigation for the lost whltewater area will have to be found on another river such as the Tuolumne, and that you will have to seek authorization from Congress for such a program. The Sierra Club must insist that a firm commitment from the Corps to approach Congress for authorization for such a program be included in the impact statement before it can be considered acceptable.

Response: The current status of whltewater mitigation is discussed in paragraph 27c. Whitewater boating is among the aspects for which remedial, protective and mitigative solutions are actively being sought. Implementation of any such solution will depend upon the justification and evaluation of both economic and intangible values. There is ample time remaining prior to completion of construc­ tion to develop mitigation plans, seek Congressional authorization if needed, and implement the adopted solutions.

(6) Comment: The discussion of the limestone caves in the area is less than adequate: What effect will the reservoir have on those caves which will be periodically inundated? Is there any guarantee of preserva­ tion for the Natural Bridges in the area?

Programs outlined by you for mitigation of environmental losses along the lower Stanislaus River and for preserving limestone caves around the reservoir, particularly at your meeting March 2 in Modesto, reduce, but do not remove, our concerns in these areas. Your statement that sufficient authorization has been provided for these programs from the Chief of Engineers is encouraging.

Response: Some effects on the caves are presented in para­ graphs 22, 28 and 29. Additional Information is presented in comments and responses of the National Speleological Society Task Force evalu­ ation of the Draft EIS. One effect on the caves that will be periodically Inundated will be resolutioning, causing fossil-containing assemblages to break off, offering an unusual opportunity for subsequent research. Caves which undergo resolutioning also offer an opportunity for research on the reverse process to speleolothem growth. The lower natural bridge will be within the project boundaries and Is at about the gross pool level. It is not expected to be adversely affected by subsidence, as was feared at Arches National Monument near Lake Powell, because of the configuration of the land and Infrequency at which gross pool is reached.

The upper natural bridge is larger, more aesthetic and has sustained little vandalism. It is located outside the approved project boundary and could be vandalized because of easier access by boat. Authority has been obtained for a study and report on the feasibility of extending the project boundaries to include such features. Plans for public access, protection and recreation uses for the caves and bridges will be Included in the New Melones Lake master plan. The Corps is working with the National Speleological Task Force to protect these unique natural resources.

(7) Comment: The project presently has a B/C ratio of only 1.2 to 1 for a 50 year period, and the interest rate is unrealistically low. How much money is available for mitigation? Is it true that only two million dollars can be spent on any one phase of mitigation before the approval of the office of the Corps of Engineers is required?

Response: As stated in paragraph 11, the project has a benefit-cost ratio of 1.7 to 1. The interest rate used was that which was used in the presentations to Congress for initial appropriation of construction funds. This procedure has been followed in the past through­ out the Corps of Engineers program and has been tacitly accepted by the Congress. The procedure is considered proper since it represents con­ ditions at the time commitments must be made. Construction funds were first appropriated for the project in 1964. Any significant mitigation proposal would require approval of the Chief of Engineers.

(8) Comment: The question of guarantees of various types of mitigations is a troublesome one, especially when it is not clear which type of mitigation is the most desirable, but I think you can understand our reservations about anything other than a firm guarantee of mitigation. The best intentions of many agencies have been destroyed by the Office of Management and Budget or by Congress. Response: See response to similar comment 3 by Environmental Defense Fund* Coordination efforts by the office of the Chief of Engineers with both the Executive and Legislative Branches of the Federal Government do not reflect the destructive conditions cited.

(9) Comment: We urge that the project be reevaluated in light of the new proposed Water Resources Council Guidelines regarding the construction of water projects* These guidelines are evidently the way society now wishes to look at water projects, and the New Melones project is not so far along that it cannot be reconsidered*

Resjjonse: See response to EDF comment 14.

(10) Comment: New Melones will be operated by the United States Bureau of Reclamation as part of the Central Valley Project when it is completed* The Corps has demonstrated no ability to bind the Bureau to Corps commitments once the project has been completed with respect to alternative uses of New Melones water. The Bureau should at least co­ author the Environmental Impact Statement*

Response: As indicated in response to comment 8 above and in response to Environmental Defense Fund comment 15, actions taken during development and construction of the project will be continued by the responsible agency whether this is the Bureau of Reclamation or the Corps of Engineers.

(11) Comment: Mr. H. E. Horton, Assistant Regional Director for the Bureau of Reclamation, speaking on behalf of Regional Director Pafford, at the March 2 (1972) meeting in Modesto, offered a most disappointing explanation of Bureau intentions toward operation of the New Melones project. Mr. Horton said the Bureau Intends to honor all commitments of the United States toward use of New Melones water, but specifically avoided terming them commitments of the Army Engineers.

Response: The utilization of the conservation yield from the project is the responsibility of the Department of Interior and no commitments will be made by the Corps of Engineers regarding such use.

(12) Comment: He furthermore said, "As operation of the New Melones project is some 6 years away, it is premature new to define precisely the exact operating details and their specific impact on the environment. These will be firmed up within the next few years. Prior to initiation of operation, a supplementary environmental state­ ment will be prepared by the Bureau." From the beginning, the Sierra Club has urged the Corps to provide a thorough analysis of the New Melones project, and of the alternative uses of New Melones water. We have specifically asked for an analysis of the East Side Project and its environmental impact. Mr. Horton suggests such an impact study will not be undertaken until the project is nearly completed, a position which is totally unacceptable to the Sierra Club.

Response: As declared in the EIS and in response to other comments (see especially EDF comments 1, 2, & 87), the Corps of Engineers is the construction agency and the Bureau of Reclamation is the operating agency. Plans and designs are prepared for each phase and coordination is accomplished between the agencies. To the extent that operational details are known these are included in the EIS. Although many details remain to be specified, there is adequate information at the present time to determine any significant effects upon the environment and other applicable requirements of the National Environmental Policy Act. An EIS, to be prepared and filed by the Bureau of Reclamation prior to operation of the completed project, will Include additional envlronemntal evaluation on the basis of Information available at that time.

(13) Comment? The comments of the Environmental Defense Fund are generally In accord with ours. We urge you carefully to consider the points raised by Mr. Meral, who is also the Chairman of the Sierra Club River Conservation Committee.

Response; EDF comments have been considered and responses prepared.

(14) Comment: We reject the use of "unreconciled conflicts" in an Environmental Impact Statement, although we realize that such conflicts may actually exist. We believe that they should be resolved before the project goes forward. Therefore, in accord with the policy of the Northern California Regional Conservation Committee, I request that all work on the New Melones project cease until the following conditions have been met: (1) That alternatives to the project be given an honest and careful evaluation, and the one which is best justified on both economic and environmental grounds is chosen; (2) The final Environmental Impact Statement is on file with the Council on Environmental Quality for at least 30 days; and (3) The "unreconciled conflicts" mentioned in the Impact Statement are resolved by the Corps, the Bureau of Reclamation, the State Water Resources Control Board, and other responsible government agencies. This should include the Congress if necessary.

Response: Unreconciled conflicts are included in the EIS (paragraph 51) to Indicate those areas in which agreement could not be reached (see EDF comment 89). Alternatives have been evaluated, and the environmental statement will be transmitted to the Council on Environmental Quality. 14. YOKUT WILDERNESS GROUP. SIERRA CLUB

(1) Comment: Studies and recommendations respecting management of the riparian habitat, flows, salmon gravel protection, public access to be provided by the Corps of Engineers, a master plan for levees and the stabilization of Woodward Reservoir with New Melones water be com­ pleted and authorized before further construction on the dam.

Response; It is considered desirable to file the environ­ mental statement based on known data and available information. The Corps position is that a detailed plan need not be adopted prior to filing the environmental Impact statement due to the need for extensive coordination with various agencies and local citizens. A tentative plan concept has been selected and is presented in paragraph 9. Woodward Reservoir is discussed in response to San Joaquin and Oakdale Irrigation District comment 4.

(2) Comment: Studies and recommendations for mitigating the loss of white water above New Melones Dam be completed and authorized before further construction on the dam.

Response: The Corps position is that studies of white water mitigation need not be completed prior to submittal of the EIS. Conclusions of studies and resulting recommendations to date are presented in paragraph 27c.

(3) Comment: Studies and recommendations for protecting caves and historical sites such as gold mines and Indian villages be completed and authorized prior to further construction on the dam.

Response: Historical and archeological resources are evaluated and salvaged as determined by the National Park Service, and the status is discussed in paragraph 28. Caves in the vicinity of the new lake are under study and coordination with the National Speleo­ logical Society and others is underway. It is considered that the natural resources values and public use of the caves are Important project-connected attributes and will be included in the Master Plan for recreation resources now being prepared. Final details of the cave resources associated with the project have not yet been prepared. It is the Corps position that final plans need not be com­ pleted prior to submittal of the EIS.

(4) Comment: A thorough analysis of the environmental Impact of the possible uses of the so called new water from New Melones, Including Its use after conveyance In the proposed East Side Canal, be completed before further construction on the dam.

Response: Possible uses of the New Melones conservation yield are discussed in paragraphs 4 and 30. The East Side Canal is not authorized and in-depth discussion of the use of the conservation yield will be provided in the EIS to be prepared by the project operator (USBR). No new Federal diversion structures will be constructed prior to prepara­ tion of a separate EIS and Congressional authorization. Without new diversion structures, the conservation yield could flow into the delta as discussed in paragraph 30. 15. STOCKTON AUDUBON SOCIETY

(1) Cerement; The project, in effect, suggests a trade-off of 10,000 acres of riparian land and 16 miles of river for the benefits gained In Irrigation, flood control, recreation, wildlife enhancement and water storage.

Response: Hie amount of riparian land to be Inundated Is about 1,000 acres,not 10,000 acres. A discussion of present land uses within the gross pool of the new Idee Is contained In paragraphs 5 and 32.

(2) Comment: The report Is hard put to justify the destruction of 10,000 acres of riparian land as being consistent with wildlife enhance­ ment. The 2000 acres offered as mitigation do not compensate, they exist already and are not being created by the dam.

Response: Fish and wildlife enhancement are specific purposes for which the project was authorized. Uildlife enhancement activities will take place on the lands acquired and made available for public use surrounding the new lake. We have been advised by the Federal and State fish and wildlife agencies that the 2,500 acres (Peoria Mountain) along with planned Improvement measures will provide substantial mitigation for wildlife displaced from upland areas by the new lake. This area Is not presently reserved for wildlife as it will be with the project. As explained In paragraph 9, wildlife mitigation for riparian wildlife will be provided on the lower Stanislaus River.

(3) Comment: It is claimed that fishing will be enhanced. According to a report by the Fish and Game Department in Outdoor California Vol. 32:6 Page 10, there has been a serious decline in fishing in the Trinity River since Trinity and Lewiston Dams were built. Efforts to restore fishing have not been successful on the Trinity, why would they succeed on the Stanislaus. It is claimed fishing will improve if mining of gravel and water diversions do not occur below the dam. There is no concrete plan for preventing mining of gravel or water diversions.

Response: The new lake will provide fishery enhancement. Fishery enhancement in the downstream area will also result from increased flows, gravel acquisition, increased public access and other measures as discussed in paragraph 9. Conditions on the Stanislaus River are not comparable to those on the Trinity River but are more coup arable to conditions on the Tuolumne and Mokelumne Rivers.

(4) Comment: Hie following reservoir recreation areas are in the vicinity of New Melones: New Don Pedro, Lake McLure, New Hogan, Camanche, Pardee, Woodward, Farmington and Tulloch. The reservoir at New Melones will offer nothing that these do not already offer and will destroy the unique recreation that the Stanislaus does new offer - white- water boating. Response: New Melones Lake will provide several functional purposes and a great many resulting benefits, as discussed in Section 1. Although recreation use of New Melones Lake will be Important, it is included in the project primarily to take advantage of the new resource to be created for the other purposes. The recreation resources noted in the comment have been taken into account in estimating the additional recreation use anticipated at New Melones Lake.

(5) Comment: For what crops? Crops already supported by govern­ ment subsidy? Where in southern San Joaquin Valley? The Friant-Kern Canal serves much of this area, why two canals? What crops in the Farmington - Calaveras area? It appears that only marginal land could be brought into production in this area.

What is the land ownership in the area to be irrigated? As we under­ stand the law, a married couple can only irrigate 320 acres with Bureau of Reclamation water, the rest of the land must be sold. Thus if the land holdings are in the hands of a few owners (as is surely the case in Kern, Madera, and Tulare counties) irrigation water will lead to land being sold off for development, not agriculture as claimed.

Response: Justification for the New Melones water yield is based on net projected demands for water in the Central Valley of California. Conveyance to areas having immediate and near-future needs is the responsi­ bility of the U. S. Bureau of Reclamation and local districts. A general discussion of the needs, possible service areas, means of conveyance and the alternative of using the yield for flushing flows in the Delta are discussed in paragraph 51.

Prior to initiation of project operation, the U. S. Bureau of Reclama­ tion will prepare an environmental impact statement on the various aspects and impacts of the use of the conservation yield from the project.

(6) Comment: What is the nature of the $50 million flood? What damage and to what? It is stated that suburban Oakdale, Riverbank, and Ripon could be protected by levees (cheaper and less damaging to the environment.) What dams now exist on the Stanislaus and other rivers that did not exist in 1906, 1938, and 1952 which are cited as high flood years.

Response: The basis for determining flood control benefits are presented in paragraph 10. The damages which would be prevented by New Melones Dam during a major flood along Stanislaus River, along the lower San Joaquin River, are presented in paragraph 26. These esti­ mates of damages are based on current conditions of development in the flood plain and take into consideration existing dams and other flood control facilities. The alternative of constructing levees is discussed in paragraph 43a. (7) Conment: The report states that £lood control Is needed to provide protection for agricultural and other development of the flood plain down river from the dam. Then it states that such development is undesirable and good local planning and zoning would be needed to keep it under control. The Engineers won't be around to see that this good local planning and zoning takes place.

Response: This comment results from the circumstance that studies of plans to be inplemented on the lcwer Stanislaus River were not sufficiently advanced by Decenfcer 1971 to be discussed in detail in the draft EIS. Studies have progressed as discussed in paragraph 9, and the Corps of Engineers is proceeding to implement the most acceptable plan for protection of the river's resources. In addition to the Corps* efforts, local planning and zoning will still be needed for control of any developments adjacent to the Corps' river protection plan.

(8) Comment: What will happen to the natural process of soil formation by silt on the flood plain when periodic floods are stopped? The reservoir will trap 10,000 acre-feet of sediment in 100 years. Fertilizer is suggested as a substitute but fertilizer is expensive and often leads to water pollution through runoff of phosphates and nitrates.

Response: At present, Melones, Tulloch and Goodwin Dams prevent sediments from reaching the lower river. Although capacity has been Included in New Melones Lake to accumulate expected sediments, these sediments would not reach downstream areas under existing conditions. See response to Environmental Defense Fund's Comment 86.

(9) Comment; No legitimate need for the stored water is mentioned. Most of it appears to be supply for the East Side Canal Project which is neither authorized nor justified. This canal would bring water to areas around Fresno and Bakersfield to grow oranges, grapes, and cotton (see feasibility report as submitted by the Bureau of Reclamation.) There is great danger that building the New Melones Dam would later be used as a justification for building the East Side Project.

Response: Need for stored water is presented in paragraphs 4 and 30.

(10) Comment: The Delta Water Quality Decision 1379 is also offered as a use for the storage water (the water would be used to flush the Delta). That decision will be a long time in the courts and should be settled before it is used as a reason for building a huge dam.

Response: Possible use of water from New Melones Lake to satisfy the requirements of Decision 1379 will be fully discussed in the environmental statement to be prepared by the Bureau of Reclamation on operation of the project. (11) Comment; The cost-benefit ratio Is l w and Is based on an unrealistic interest rate of 3-1/8% on questionable recreational use, and on delivery of water to contractors who may not want or need that water. Have monies been allocated to the Bureau of Reclamation to develop the recreational facilities from which the benefits will supposedly arrive? Recreation is not the true function of the Corps of Engineers.

Response: Information answering most of this comment is con­ tained in paragraphs 8 and 11 of the EIS and in response to Environmental Defense Fund comments 15 and 25. Public Laws 78-534, 87-874, and 89-72 all specify that recreation is a function of the Corps of Engineers.

(12) Comment; The cost is immediate and the benefits, if any, 'are in the future. Have the benefits been calculated to take into account dollar shrinkage due to inflation? Have the costs of moving part of Hwy 49 and other county roads and the costs of the destruction of the Old Dam and powerhouse been added into the cost?

Response: The costs and benefits were updated in 1971 and are presented in paragraph 11. Benefits are discounted at a 3-1/8% Interest rate to account for immediate cost versus future benefits. Relocations are included in the project cost, as are the costs of the existing Melones Dam and powerhouse.

(13) Comment; "There would be a 40 foot drawdown between Memorial and Labor Day. There would be a visible exposed soil gap of less than 50 vertical feet from clearing line to the water surface." The term vertical feet is meaningless. Average horizontal feet would be meaningful and show the extent of the denuded area. A treeless reservoir with denuded banks hardly seems to "increase the scenic value of the area."

Response; The extent of reservoir lands exposed at a 50 foot and 260 foot drawdown is included in paragraph 35.

16. NATIONAL SPELEOLOGICAL SOCIETY

(1) Comment; The Indian Petrogyphs are not in a cave but on the face of the cliff about 100 feet above the river and approximately 3/4 mile upstream from the Parrott's Ferry Bridge on the north side. They will be inundated but could be viewed during periods of l

Response; Noted in EIS.

(2) Comment; It might be mentioned that spelunking as a recre­ ational resource is unique in that it is a year round sport. Extremes of tenperature are nullified since the temperature in a cave varies less than two degrees and is for all practical purposes the mean outdoor temperature. Being above the fog zone and below the snowline, caves in the area average about 56 degrees. Daylight is also not required for the sport. Caves present conditions of nearly absolute darkness and silence.

Response: This information is being used in preparing the master plan for New Melones Lake which will include consideration for recreation use of the caves.

(3) Comment: Some abandoned gold mining equipment is located on the south side of the South Fork below Pine Log. An unusual rotary stamp mill is included and probably will be pilfered when the reservoir rises. It should be removed to a museum.

Response: Consideration is being given to salvage of this and other historical items affected by New Melones Lake, both by the National Park Service and in current studies by the Corps for the master plan for recreation.

(4) Comment: Since the roof of the entrance room of McLean's Cave seems to be composed of a red clay composite material cemented by calcite, it may represent a formerly open sink hole. If so, it could contain a fossil assenblage dating either to the pleistocene or late pliocene geological eras. The resolutioning that will occur could cause this to break off in chunks and fall to the floor of the cave where archeological and paleontological research could be performed. This should be another reason for proper gating techniques of the inundated cave (i.e., fine meshed screen).

Caves below gross pool will undergo extensive solutioning and resolu­ tioning since the fresh water will be greatly undersaturated with Calcium and Magnesium ions. In addition, sulfate minerals in the inundated mines and mine tailings will probably generate substantial quantities (at least as far as the basic limestone is concerned) of sulfuric add. If this gets to be a significant problem, it could lead to the collapse of some poolside caves and be a possible hazard to boating, swimming, etc.

This accelerated solutioning could be used as an interesting study in speleogenesis. The resolutioning or reverse process to speleothem growth, although regretted, could in this instance also present an unusual speleostudy opportunity. These opportunities, also, are reasons for proper and controlled entry into the caves through gating techniques in a geological preserve.

Response: Possible hazards and other appropriate informa­ tion concerning study and public use of caves will be included in the master plan. The National Speleological Sodety's Stanislaus Caves Report, expected to be available by July 1972, will contain specific recommendations regarding study and protection of the caves. Actions to be taken by the Corps of Engineers will be described in the master plan.

(5) Comment: Ihe reproduction of skeetens, a principle in the diet of bats, will be Increased by the reservoir. This should lead to potentially increased bat populations. Both from the point of view of preserving the bats (which have been decreasing in population in the United States), and for safety's sake in rabies control; the recreational opportunities should be controlled and interpreted by a geological preserve.

Response: See response to NSS Comment No. 2.

(6) Comment: Amongst the wildlife that will migrate as the water rises is the rattlesnake. They exist in great numbers in dens near the river and may affect adjacent landowners adversely by their unsettled presence. This fear was expressed to me recently bv a Calaveras County cattleman. If the water rises rapidly during very cold weather, (hibernating time), the snakes would probably drown; but if the rise is later during the warmer weather of the snow melt period, they could present some hazards.

Response: This is a very real hazard, and has been a concern at other newly filling reservoirs. Posting of cautionary notices is a useful public safety measure and this device will be used at the appropriate time for New Mel ones Lake.

(7) Comment: There is little evidence that the larger living organisms within the caves to be inundated will migrate. The ecology of the caves is very confining as well as fragile. I believe that inter­ ested persons may be available who could collect specimens prior to inundation for the purpose of relocating them to similar caves above gross pool. If a geological preserve s created soon and a committee of qualified speleologists is appointed in an advisory capacity, as recommended, they could coordinate many such activities and studies with a minimum of "fanfare" and expense to the governing agencies.

Response: This and related matters are being studied in conjunction with preparation of the master plan. Coordination is continu­ ing with Mr. Squires and others to arrange for relocating any unusual and inportant fauna from caves to be inundated.

(8) Comment: Thank you for this chance to comment. I under­ stand that we will have a chance to make a formal response to the final edition. The final printing of our Report of Study, presently being revised and upgraded, will probably be available by that time and could be forwarded as an addendum to the EPA. I have attempted to keep your staff aware of any findings that I have made. Response: This environmental statement will be forwarded through the Secretary of the Arny to the Council on Environmental Quality. Upon submittal to the Council, copies will be made available to the public in accordance with prescribed procedures.

17. CITIZENS ENVIRONMENTAL ADVISORY COMMITTEE

Comnents solicited but none received.

18. THE WILDLIFE SOCIETY. SACRAMENTO CHAPTER

(1) Conment: The draft EIS supplies the nunber of acres of wildlife habitat that will be inundated but there are no nuirbers or esti­ mated lumbers of wildlife populations involved in this 10,700 acres. It is difficult to assess the environmental Impact of this project without knowing such data.

Response: Available authoritative population figures have been included in paragraph 20.

(2) Comment: Since the 4,719 acres of mitigation land is located in the same general area of the project, it is assumed that the mitigation land is presently carrying about the same density of wildlife as the land to be inundated. If this is so, how can 4,719 acres of land which already has a wildlife population on it, mitigate for the loss of 10.700 acres of habitat? The report leads one to believe that "wildlife cultural practices" used on the mitigation lands will enable this 4,719 acres to not only sustain the wildlife population it already has, but also to support the additional nunber of wildlife displaced from the 10.700 acres Inundated by the reservoir. This is highly unlikely and very misleading to those readers who are not knowledgeable with wildlife management.

Response: The wildlife mitigation plans have been adopted based on evaluation of the recommendations of the Federal and State fish and wildlife agencies who are responsible (Public Law 85-624) to provide such recommendations.■ It is understood that the carrying capacity will be increased by the cultural practices also recommended by those agencies, and substantial mitigation (offsetting potential losses) will be achieved. The existing lands are not being managed for wildlife and consequently have a lower carrying capacity. That complete mitigation will not be achieved is recognized and discussed in Section IV - "Adverse Environmental Effects Which Cannot Be Avoided."

(3) Coianent: Although "wildlife cultural practices" such as removal of or other manipulation of the old stands of chaparrel will enhance most wildlife habitat, the EIS did not Indicate how this on-going management activity was to be financed. Without a program and plan for financing these on-going wildlife management activities, such activities will lag behind and the wildlife displaced from the 10,700 acres will surely disappear.

Response; The Corps of Engineers will acquire the mitiga­ tion land and finance the Initial development of the wildlife management area. Development of the wildlife management area will be completed prior to conpletion of the main dam in 1978. Following initial develop­ ment, operation and maintenance of the wildlife mitigation lands at the reservoir would be the responsibility of the Bureau of Reclamation or an agency designed by the Bureau.

(4) Comment: To offset such a direct loss of wildlife, it is the recommendation of the Sacramento Chapter of the Wildlife Society that the riparian land for several miles below the damslte be acquired for wildlife purposes. Publicly owned riparian wildlife habitat is at a premium throughout the foothills and in the San Joaquin Valley. This uniquely located land would be a tremendous asset to fish and wildlife as well as providing access and space for other recreational purposes.

Response: This comment reflects the similar previous comment of the Federal and State fish and wildlife agencies. Alternative plans for the lcwer Stanislaus River and acquisition of riparian lands is discussed in paragraph 9.

19. AMERICAN RIVER TOURING ASSOCIATION

(1) Comnent: (Considerable discussion is contained in the letter from the American River Touring Association dated 1 March 1972, which is appended to this EIS. Their concluding or summary comment is as follows:) My recommendations, then, are to abandon the proposed New Melones Dam in the absence of any viable mitigation for the river oriented public. The projected benefits of reservoir recreation for the dam project, however well supported by statistical fact or fancy, are unreal­ istic and destructive of more relevant social values. They should be struck from the current benefit-cost ratio used to justify dam construction. Finally, the Army Corps of Engineers must prove full consideration of alternative damsltes and other methods for providing basic flood control. To paraphrase Ron Hayes of Los Angeles, the real task is not to seek alternatives for the wild river enthusiast. Rather, we must seek a workable alternative for the New Melones Dam.

Response: The EIS is an objective presentation of the detriments and benefits of the multipurpose New Melones Lake project and various alternatives available, and reflects the interests of all concerned parties. In recognition of affected environmental aspects, the Corps of Engineers has developed remedial, protective and mitigatlve measures and, where these are within the framework of the authority granted to the Corps of Engineers, they have been Incorporated into the construction program for the entire project. It is acknowledged that all Interests cannot be completely satisfied by these measures and that some trade­ offs will result from this multipurpose project.

20. WILDERNESS WORLD

(1) Comment: The proposal to build the New Melones Dam first was made some 25 years ago under the Flood Control Act. If flood pro­ tection was the main purpose, we have lived without it these last 25 years - which indicates there is no real urgency to this purpose. What have been the actual costs in flood damage to the lands directly affected? What are estimated costs from this supposed threat? What percentage does this water system contribute to the overall valley flood threat? Is it really appreciable?

Response: Within the last 25 years there have been at least nine major floods on the Stanislaus River. ' These floods caused estimated damages along the river between Melones Dam and the San Joaquin River of over $7,500,000. During these same floods damages of over $12,500,000 were estimated to have occurred along the San Joaquin River below the confluence of the Stanislaus River and in the upper San Joaquin Delta. A significant amount of the damages occurring along the lower San Joaquin River and Delta are attributable to flews from the Stanislaus River. The damages along the lower San Joaquin River and Delta con­ tributed to by Stanislaus River flows is variable, but appreciable. A percentage of the damages along the San Joaquin River attributable to Stanislaus River floodflows is not available because the coincidence of peak flows from the two river systems cannot be accurately predicted.

(2) Comment: In the listed alternatives, channel and levee improvements are dismissed as "expensive." What does this mean in actual costs? How do they compare with the $180,000,000 estimated costs for the dam - and the loss of the whitewater recreational area?

Response: Costs and additional discussion of these alternatives are presented in paragraph 43a. Public recreation values of whitewater boating are estimated in the order of $200,000 annually, based on the most liberal unit value presently permitted— $6.00 per day of boater use— and the estimate of use provided by Mr. Meral (see Environmental Defense Fund comment 36) and a modest growth potential; if growth in use would reach the proportions estimated by Mr. Meral (Environmental Defense Fund comment 37), the value would be in the order of $400,000 annually. As a further comparison, total benefits for all functions of New Melones Lake are estimated at $12,000,000 annually. (3) Comment: On page 84 acknowledgment Is made that the annual runoff Is beneficial to the soil of the valley, but it is stated that chemical fertilizers can take the place of this. There are grave ques­ tions as to whether chemical fertilizers can ever replace this natural process, and as to their effect on the produce as well as on the soil. Have these possible costs been taken into consideration in establishing a cost-benefit ratio?

Response: Existing Donnells, Beardsley, Tulloch, Melones and Goodwin Dams presently trap most of the silt and soil nutrients that were historically deposited on the flood plain. Additional reduction by New Melones Lake would have only a slight effect.

(4) Comment; The economic direction which will be given the area with the building of the dam has been touched upon only superficially. It has been pointed out that some of the crops which are most suitable to the area already are on the surplus list and are being subsidized by the government. As far as real estate development is concerned, the denser housing which may result will change the character of the surrounding area considerably, with attendant problems of waste disposal, air pollution, etc. The long-term economic forecast should include these factors as well as short­ term increases in property values.

Response: The discussion of impact from secondary develop­ ment that may be stimulated by the project has been expanded in paragraph 32.

(5) Comment: The entire question of evaluation of recreational activities is presently under study by various government agencies and private institutions working under government contract, e.g., evaluation of rivers for possible inclusion in Wild and Scenic River System under Department of Interior, Office of Water Resources. The present trend is to value usage in terms of quality rather than quantity alone. A wilder­ ness experience such as a river tour on a whitewater river, for example, would rate considerably higher than a corresponding number of days spent on a crowded, man-produced lake, water-skiing behind a motor boat. Although both types of recreation hold a different subjective value for the indi­ vidual involved, it is felt that an overall estimate of value for the average citizen can be placed on these activities. Because of the rareness of the experience and its contrast to the pressures and unaesthetic features of modern urban life, the wilderness river tour ranks high in recreational, refreshment value, as compared to the activities which would be available on a man-made lake. We believe that no further evalua­ tion of cost-benefits is possible without recourse to the most recent studies on this subject, and we ask for inclusion of these factors in any final environment report. Response: The concept of much higher values for recreation activities in short supply, such as whitewater boating, than for recreation activities more abundantly available is valid. Recreation benefits at New Melones have been computed on the basis of one dollar per recreation day. As noted in response to comment (2) above, whitewater boating could be valued up to $6.00 per recreation day, which is the maximum possible rate by Congressional policy (69). On this basis the recreation benefits of New Melones project greatly exceed the economic value of recreation activities to be lost. Furthermore, New Melones project is economically justified even if no recreation benefits are included.

(6) Comment: Historical and archaeological values also should be reexamined. How does the experience of standing beneath the arch of an old and beautiful Indian cave, sculptured by the river, and running one's hands over the indentation in the bedrock worn by the hands of Indian women grinding acorns long ago, compare to looking at a rock under glass in a well-lighted visitor center?

Response: Presently most of this area is on private lands and not open to the public. The new lake will inundate 10 of the more than 70 caves in the project area. Many of the remaining caves will be available for visitation and appreciation by the public. The Corps of Engineers, with the aid of a National Speleological Society Task Force, is investigating possible methods of providing increased public recreation use of the caves and natural bridges and protecting them from vandals. Methods such as gating of the more lcqportant caves and providing tours to the public are being considered. Artifacts and other archeological and historical resources surveyed and salvaged by the National Park Service will be studied and will Increase scientific knowledge in this area. Some artifacts will be available for.display to the public.

(7) Comment: What is the educational value to youth of seeing with their own eyes the spots where Mark Twain rambled, or finding the remnants o'f an old mining enterprise along the river? Does it not seem ironic to inundate these historic spots, and then name a visitor center after Mark Twain? (He would appreciate the irony, and no doubt have some withering comment, but unfortunately we are denied the pleasure of adding his name to the list of those who hope to save the Stanislaus.)

Response: Since the days of Mark Twain numerous changes have taken place in this area, including the construction of reservoirs, freeways, subdivisions, etc. The old mining enterprises along the river are hazardous, are on private lands and are not open to the general public. Although the new lake will inundate some historic values as discussed in paragraph 28, the efforts to preserve, mitigate and make such resources available to the public will result in a net increase in availability of these values. (8) Comment; Perhaps we can gain others, however. The only true public meeting on this subject was held 12 years ago, In 1960 - except for some small local public meetings held in the area, mainly . with persons interested in real estate development. In the meantime, there has been a fundamental change in public thinking on conservation, ecology, and wilderness values. And in the meantime, the Stanislaus has gained the stature of a national resource; a lovely stretch of whltewater which is one of the most popular river runs in America today. No decision should be made on its future without thorough public understanding of the issues involved, and without greater expression of the public's views.

Response: A nunber of public meetings have been held throughout the investigation and post-authorization stages of the project (see paragraph 48). The most recent public meeting was held in Modesto on 2 March 1972 at which all interests had an opportunity to express their views. Additional meetings will also be held. According to publications of the Sierra Club and others, there are numerous whltewater boating opportunities elsewhere in California and in the Nation. It is possible there are other opportunities presently unrecognized or museable due to access or other problems, subject to correction. Many such opportunities are, however, of a different type, available to different segments of the public and otherwise not directly comparable to Stanislaus River. 21. STATE OF CALIFORNIA

(1) Comment: (Refers to paragraph 10 of Draft EIS.) The use of "San Joaquin River" as the lower terminus could be interpreted to mean the bacicwater of the San Joaquin on the Stanislaus. We suggest that language be modified to eliminate any doubt as to the downstream end of the reach to be maintained. The Corps' channel maintenance requirement should apply to the entire length of channel from Goodwin Dam to the mouth of the Stanislaus River.

Response: The £IS has been modified as suggested for clarification.

(2) Comment: The statement indicates that private levees will be included in the floodway to contain flood flows of 8,000 cfs and will be maintained by nonfederal local interests. By including such levees, the levees in effect become project levees and rights-of-way therefore would be acquired by the Reclamation Board. We believe that some of the private levees may not be adequate to carry the design flow. It may be necessary for the Corps to strengthen some reaches of the private levees to make sure that they will carry the 8,000 cfs.

Response: The comment above appears to accurately reflect future needed actions by the State to fulfill the proviso concerning maintenance of private levees and prevention of encroachment on the existing channel and floodway between the levees as specified by Congress in the Flood Control Act of 1962. The Corps has recognized that some of the private levees will not be adequate to contain the 8,000 c.f.s. flow. Consequently, to aid the State Reclamation Board in fulfilling their responsibility of providing assurances to maintain private levees along the river, the Corps of -Engineers has identified those private levees considered adequate to contain a flow of 8,000 c.f.s. and furnished this information to the Reclamation Board with instructions that the levees so identified are to be maintained as a part of the non-Federal participation in the project. The Flood Control Act of 1962 provides no authority for the Corps of Engineers to improve the levees along the Stanislaus River, and no such Federal improvement is planned.

(3) Comment: The statement indicates that a study was initiated late in 1970 to determine the need for possible acquisition of riparian lands downstream from the reservoir for fish and wildlife mitigation and enhancement, public access, recreation, and related purposes. We suggest that the need for rights-of-way for channel maintenance should also be determined.

Response: It is believed that rights-of-way for channel maintenance, since this will be an intermittent activity, can be obtained by means of a right-of-entry permit from landowners. This, in conjunction with the requirements of non-Federal interests (The Reclamation Board) to preserve the floodway by preventing encroachments between the levees, is considered adequate for channel maintenance requirements. Alternative plans for downstream riparian land preservation, along with plans for the preservation of fish spawning gravels and provision of public access, are discussed in paragraph 9 .

<*o Comment: The Bureau of Sport Fisheries and Wildlife recommended in its January 25, 1971, report on the project that the Corps acquire in fee title or easement all lands inside the levees below the 8,000 cfs flow line between New Melones Dam and the confluence of the San Joaquin River. The Department of Fish and Game concurred in this recommendation. These lands would be an integral part of the wildlife mitigation program to offset project-associated losses of habitat caused by reservoir inundation (10,700 acres) and accelerated land development along the river. The State Lands Commission notes that any such acquisi­ tion program should take into account the existing public ownership and rights in land in the bed of the river. Acquisition of these lands is also important to the preservation and enhancement of Stanislaus River anadromous fisheries. The Department of Fish and Game acknowledged in 1964 that, with anticipated post-project streamflows and protection of existing spawning gravels, an increase in fish runs of 8,000 king salmon and 1,500 steelhead would occur. The annual monetary value of this increase is $1*24,000— an enhancement credit to the project. The impact statement acknowledges the need for acquiring riparian lands for these purposes. Since the final decision, however, "to acquire" or "not to acquire" has been delayed pending completion of the land acquisition study that was initiated late in 1970, there is no assurance that the wildlife losses will be adequately mitigated or that the $1*24,000 annual fisheries enhancement benefits will occur.

Response: As discussed in paragraph 9, a plan for mitigation and enhancement of fish and wildlife resources combined with public access provisions and the requirement for maintaining the existing floodway to a capacity of 8,000 c.f.s. will be implemented by the Corps of Engineers as authorized. Of the alternative concepts developed, one alternative or combination of alternatives will be selected that best fits the require­ ments and objectives for the lower Stanislaus River, in consonance with the needs and desires of the majority of the people and agencies concerned, including the State and Federal fish and wildlife agencies.

(5 ) Comment: The first problem is anadromous fisheries enhance­ ment as related to streamflow in the Stanislaus River. The previously mentioned $ 4 2 4 , 0 0 0 annual enhancement benefits to the project cure contin­ gent on several factors, including high post-project streamflow. The statement indicates that if the new water yield is transported via the Stanislaus River to the Delta, then average monthly flows in the river would range from 500 c.f.s. to 1 , 0 0 0 c.f.s. January through August, and from 200 c.f.s. to 1*00 c.f.s. September through December. With these flows, we believe that the predicted salmon and steelhead enhancement would occur. If the water is diverted, however, at Knight's Ferry to the JSast Side Canal or similar conveyance system, then the Stanislaus River flows below Knight's Ferry would range from I30 c.f.s. to 1*00 c.f.s. January through August, and 130 c.f.s. to 200 c.f.s. September through December. Despite our I96I* finding, we now believe that anadromous fish­ eries enhancement would not occur at these flows— hence the $1*2U ,000 annual fishery benefit would not accrue to the project.

Response: This comment is not consistent with advice received from the Bureau of Sport Fisheries and Wildlife as reported in paragraph 3 1 of the iSIS. This matter will be given further study and attention in an effort to determine the validity of both the 1961* data and recent information. Resolution of this matter will be described in revisions to this £IS and in the £IS prepared by the Bureau of Reclamation on operation of New Melones.

(6 ) Comment: The second problem is the indirect effect on wildlife in potential service areas. The Corps predicts that the new water yield could irrigate 100,000 acres of presently uncultivated, wild lands. Additional wildlife habitat losses could occur as a result of land use change. The State recognizes that use of this water may not result in a land use change; project water may replace waters presently pumped from the groundwater basin. The magnitude of losses would vary, depending on the specific service area, crops produced, acreage, and conveyance facilities involved. These effects must be evaluated as soon as the specific service areas are delineated. Addi­ tional wildlife mitigation measures may be necessary, contingent on the findings of that evaluation. We understand the Bureau of Reclamation will prepare an environmental impact statement on the 325,000 acre-feet of annual new water yield prior to completion of the dam in about six years. Prior to completion of the Bureau's environmental impact state­ ment, provision should be made for future acquisition of additional lands if needed.

Response: The statement regarding the 1 0 0 , 0 0 0 acres of new farmland that could be developed is misleading and has been deleted from the £ I S . A general discussion of the conservation yield is presented in paragraphs 1*, 30, and 51. The plans for wildlife mitigation being investigated result from evaluation of reports from the Department of Fish and Game and the Bureau of Sport Fisheries and Wildlife. It is understood that these comments were made on the basis of the fish and wildlife agencies' evaluation for the entire project including the effects from conservation yield in service areas. These matters will be included in USSR's £IS to be prepared before the project is placed in operation. (7) Comment: The final JSIS should expand on fire protection measures that would he provided.

Response: Contracts to be awarded on various features of construction will include provisions for fire prevention and suppression. Fire fighting equipment and personnel will be available at the project during construction. Fire protection in this area is the responsibility of the California Division of Forestry. To assist in fire suppression after project completion, the Division of Forestry made specific recom­ mendations including access roads, heliports, firebreaks, and other measures. These features for fire suppression will be Included in the Raw Malones Lake Master Plan as a part of the initial development to be constructed by the Corps.

(8) Comment: We request that a more definite presentation be included in the statement concerning the proposed recreation facilities planned for the reservoir area, including a proposed time schedule for construction. The statement indicates that studies are in progress to prepare a master plan for public recreation use. We would like the opportunity to review the plan.

Response: Details of recreational development presented are not available at this time because preparation of the master plan is still in progress. Details of the development, scheduled construction and other information will be included in the master plan; when completed a draft copy will be forwarded to the California Resources Agency for information.

(9 ) Comment; In the fall of years when flow in the San Joaquin River at Stockton is low enough to cause a dissolved oxygen "block" detri­ mental to anadromous fish, the Bureau of Reclamation and the California Department of Water Resources,under agreement with the Department of Fish and Game, has taken action to eliminate the problem. In the interest of completeness, we suggest this be recognized in paragraph 1 7 , page 20.

Response; Information concerning this joint action has been included.

(10) Comment: The £IS should include the project's long-term capacity to maintain salinity at 500 mg/l at the Vernalis station on the San Joaquin River. We are concerned that the increase in irrigation use, the increase in salinity within the reservoir due to evaporation and the out-of-basin exportation, should the 325,000 acre-feet of project yield be diverted at Knight's Ferry, might combine to negate the beneficial effects of the water committed for water quality control. Response: The anticipated effects from increased evapora­ tion and increase in irrigation water, as well as advice received earlier from the Public Health Service on the requirements for producing water quality benefits, are discussed in the EIS. The Public Health Service report takes into consideration the water quality of stream flow under conditions of water diverted from the Stanislaus River Basin. Although this information has not indicated that water quality control would be negated, the concern expressed here is noted and will be referred to the Bureau of Reclamation for evaluation in their SIS.

(11) Comment: The SIS should include the effect on the dissolved oxygen regimen of the receiving waters of the lower San Joaquin River and the southern Delta which might be caused by releases of algal-containing waters from the reservoir at critical times of year.

Response: Measures are planned to eliminate any adverse effects on dissolved oxygen if they should occur (paragraph 30 of the SIS).

(12) Comment: The effects of the virtual couplete elimination of flushing flows. We are concerned that the long-term result of this might be increased eutrophication of receiving waters.

Response: Reduction in flushing flows is discussed in paragraph 30,

(13) Comment: The SIS should include the effects of the dis­ charge of dissolved iron and manganese which may be contained in the anaerobic waters mentioned on page k 7 of the statement.

Response: These effects are not expected to significantly adversely affect the beneficial uses of water. Discussion has been expanded in paragraph 30. There are low-level water releases for power generation in existing reservoirs above Tulloch Reservoir and these have not created any problems (see paragraph 16).

(lh) Comment: The ISIS should include the effects of a single release point from the dam on temperature and other water quality factors. We feel a multi-level outlet has many potential benefits.

Response: As discussed in the JSIS, the one low-level outlet will provide improved water temperatures over.existing conditions. Water quality below Goodwin Dam will also be improved over existing conditions. If there is a need to correct a dissolved oxygen deficiency in Tulloch Reservoir, this will be accomplished. As explained in the iSIS, the costs for a multiple-level outlet do not appear needed or justified. (1^) Comment: The EIS should include the additional salinity- contributed from expanded agricultural activities in paragraph 39 on page 76.

Response: Because of uncertainties regarding the areas of use for the New Melones Lake conservation yield (see paragraphs if, 30, and 5 1 ), extensive discussion on this subject is not warranted; some addi­ tional information has been added to paragraph 39* This matter will be included in the EIS to be prepared by the Bureau of Reclamation prior to project operation.

(16) Comment; We appreciate the Corps’ efforts to create an environmentally acceptable project and will continue to work closely with the staff of the Corps to accomplish this mutual goal. We request that the foregoing comments and suggestions be incorporated and be given full cognizance in the final statement. In addition we request that the revised statement give assurance that riparian land along the Stanislaus River be acquired in accordance with the recommendation of the U.S. Bureau of Sport Fisheries and Wildlife and the State Department of Fish and Game. We request that we be given ample time in which to review the final statement. The State will expect to comment again on the final environmental statement and reserves the right at that time to also voice their opinion on the overall aspects of the project particularly as to (l) the use of the new water yield of 325»000 acre-feet per year, (2 ) a detailed benefit/cost comparison between the 1 ,100,000 acre-feet reservoir recommended in 1959 and the current recommendation of 2 ,^00,000 acre-feet reservoir and (3 ) the relationship between 1 and 2 .

Response: Alternative concepts for riparian land and associated resource protection and improvement are discussed in paragraph 9 . The views of the Federal and State fish and wildlife agencies will be evaluated in selecting the alternative or combination of alternatives to be implemented by the Corps of Engineers. The alternatives section includes the information requested. Upon submittal of the EIS to the Council on Environmental Quality, copies will be made available in accordance with adopted procedures. The Environmental Defense Fund and others filed suit in the United States District Court in the Northern District of the State of California on 8 June 1972. Their suit is a complaint for review of administrative action pertaining to the New Melones Lake project and alleges non-compliance with the National Environmental Policy Act of 1969 (NEPA). Responses are provided below to each specific complaint listed in the suit. The specific complaints are quoted from the information filed with the Court, which states that the National Environmental Policy Act of 1969 should be implemented for the New Melones Lake project by accomplishing the items shown in quotes:

(1) Comment: "by interpreting the legislation authorizing this project in accordance with the policies set forth in NEPA;"

Response: The Corps of Engineers is interpreting the legislation that authorized the project (reference number 4 cited on page B-l) in accord with NEPA policies. We believe the information in this EIS confirms this statement.

(2) Comment: "by utilizing a systematic, interdisciplinary approach to insure the integrated use of the natural and social sciences in the environmental design arts in planning and in taking decisions in respect of the project;"

Response: The Corps of Engineers has utilized an inter­ disciplinary approach to planning and design and other facets of projects, including New Melones Lake, for many years. Many disciplines are repre­ sented in the staff of the Sacramento District and when additional disciplines have been needed arrangements have been made to utilize those available from other Federal agencies, State and local agencies, expert consultants and others whenever required for the planning and design of New Melones Lake.

(3) Comment: "by giving consideration to environmental amenities and values in connection with the plannipg of the project, in addition to economic and technical considerations;"

Response: Environmental amenities and values are considered by the Corps in planning projects, including the New Melones Lake project. Even prior to enactment of NEPA, considerable effort was given to enhance­ ment and mitigation opportunities connected with this and other projects for fish and wildlife and associated resources. Primary authority for this prior to NEPA was the Fish and Wildlife Coordination Act, Public Law 85-624, and many environmental amenities for fish and wildlife resources have been considered and have been Implemented as practicable and warranted. Other amenities have also been fully considered as provided by other Federal instructions, such as preservation and protection for archeologi­ cal and historical resources and enhancement of public use opportunities. In the short time since NEPA was enacted, the Corps has responded with consideration given to a wider range of environmental amenities. Imple­ mentation of a number of such amenities specifically for the New Melones Lake project is discussed in the EIS. In addition, the District Engineer has personally sought out a variety of persons and agency representatives to obtain their views as to appropriate environmental amenities which should be considered for inclusion in the New Melones Lake project. All such views have received careful consideration and evaluation resulting in plans for implementation of those that are appropriate and within the authority provided to the Corps.

(A) Comment: "by studying, developing and describing appro­ priate alternatives to the project and its operations as presently conceived."

Response: Appropriate alternatives have been carefully studied and developed for the New Melones Lake project, and although final operational decisions are yet to be made, operational alternatives have been developed and are being studied and evaluated by the Bureau of Recla­ mation. These are reported on in Section V and elsewhere in the EIS.

(5) Comment: "In addition, defendants are required by NEPA to provide a detailed statement assessing the environmental impact of the project which must include, inter alia, a discussion of alternatives to the project."

Response: This EIS, dated May 1972, fulfills the referenced NEPA requirement and is submitted in full compliance therewith. NEW MELONES LAKE ENVIRONMENTAL IMPACT STATEMENT

APPENDIX B

REFERENCES CITED

U. S. A m y Engineer District Corps of Engineers Sacramento, California APPENDIX B

' REFERENCES CITED

1* "New Melones Project, Stanislaus River, California," House Document No. 453, 87th Congress, 2nd Session.

2. "General Design Memorandum No. 10, New Melones Reservoir, Stanislaus River, California," July 1967, U.S. Arny Corps of Engineers, Sacramento District.

3. Letter to Sacramento District, CE, 14 August 1962 - U.S. Bureau of Sport Fisheries and Wildlife - Report on the effects New Melones Lake would have on fish and wildlife resources (18 pages).

4. "Flood Control Act of 1962, Public Law 87-874," approved 23 October 1962.

5. Letter to Sacramento District, CE, from U.S. Bureau of Reclamation, 5 April 1972.

6. Statement of the U.S. Bureau of Reclamation at the public meeting held in Modesto, California, by the Sacramento District, CE, on 2 March 1972.

7. Letter to Sacramento District, CE, 30 July 1964, U.S. Bureau of Sport Fisheries and Wildlife.

8. "Effects of the New Melones Project on the Fish and Wildlife Resources of the Stanislaus River, California," 1964, California Department of Fish and Game.

9. Preliminary Master Plan, Design Memorandum No. 3A, New Melones Project, Sacramento District, CE, September 1964.

10. "Water Supply and Water Quality Control Study, New Melones Project, Stanislaus River Basin, California," January 1965, Public Health Service.

11. "Water Resources Development in California," 1969, U.S. Army Corps of Engineers.

12. "Trace Elements in Surface Waters of the San Joaquin Valley," June 1971 Memorandum Report by the California Department of Water Resources, San Joaquin District.

13. "Rivers and Harbors Act of 1965, Public Law 89-298," approved 27 October 1965 (Section 301 includes authorization for navigation project "San Francisco Bay to Stockton"). 14. House Document No. 208, 89th Congress, 1st Session, dated 17 June 1965, contains Chief of Engineers' report recommending construction of "San Francisco Bay to Stockton Project."

15. Letter from Environmental Protection Agency, Region IX, to Sacramento District, CE, dated 11 January 1972.

16. Letter from California Central Valley Regional Water Quality Control Board to Sacramento District, CE, dated 4 October 1971.

17. - "Mines and Mineral Resources of Calaveras County, California," 1962, Clark and Lydon. Resources Agency of California, Division of Mines and Geology.

18. "Interim Water Quality Management Plan, Central Valley Basin, San Joaquin River Siibbasin, Subbasin, Volume Two," June 1971, California Regional Water Quality Control Board, Central Valley Region.

19. "California Fish and Wildlife Plan," 1965, California Department of Fish and Game.

20. "Anadromous Fisheries Administrative Report No. 70-14, 1970, California Department of Fish and Game.

21. "Marine Fisheries Administration Report No. 68-12," 1968, California Department of Fish and Game.

22. "Main Water Quality Control Plant - 1969 - Enlargement and Modification Study," November 1970, a report to the City of Stockton by Brown and Caldwell, Consulting Engineers, San Francisco, California.

23. "San Joaquin Estuary Near Stockton, California - an Analysis of the Dissolved Oxygen Regimen," May 1968, Federal Water Pollution Control Administration.

24. Letter to Sacramento District, CE, from California Regional Water Quality Control Board, Central Valley Region, 4 October 1971.

25. "A Preliminary Assessment of Flora and Fauna Affected by New Melones Reservoir," 15 December 1971, Jones & Stokes Associates, Sacramento, California. (Consultant report to Sacramento District, CE.)

26. "Life Zones and Crop Zones of the United States," Merrlam, C. H . , Bulletin, U.S. Bureau of the Biological Survey, 10: 1-79, 1898.

27. "Inventory of Rare, Endangered and Possibly Extince Plants of California," California Native Plant Society, 16 July 1971. 28. "Search for Salamanders of the Genus Hydromantes in the Canyon of the Stanislaus River," March 1972, Jones & Stokes Associates, Sacramento, California. (Consultant report to Sacramento District, CE.)

29. "The New Melones Archeological Project," a preliminary report, August 1970, by the Central California Archeological Society.

30. "Draft Report of Study," November 1971, National Speleological Society, Cave Conservation Task Force, New Melones Project, Ralph E. Squire, Chairman.

31. "Register of Historic Places, 1969," and subsequent Notices published In Federal Register, National Park Service, U.S. Department of the Interior, Washington, D. C.

32. "California Historical Landmarks," 1971, Department of Parks and Recreation, State of California, Sacramento.

33. Letter to Sacramento District, CE, from National Speleological Society, 1971, Ralph E. Squire.

34. "Lower San Joaquin Valley Water Quality Investigation - Bulletin No. 89," California Department of Water Resources, December 1960.

35. "The Scenic Route - A Guide for the Designation of An Official Scenic Higiway," Transportation Agency, State of California, Sacramento, undated.

36. General Plan, Tuolumne County, 1969.

37. General Plan, Calaveras County, 1968.

38. "Presentation to the Board of Supervisors on the Values of the Stanislaus River to the Recreational and Economic Development of Calaveras and Tuolumne Counties," 1970, Presented by David A. Kay, The American River Touring Association.

39. "California Protected Waterways," February 1971, Resources Agency of California.

40. "Report on the Lower Stanislaus River," 4 August 1971, by the River Touring Section and Stanislaus River Committee of the Yokut Wilderness Group, Sierra Clifc.

41. "Plan Formulation and Evaluation Studies, Recreation - Technical Report No. 2 - Estimating Initial Reservoir Recreation Use," October 1969, U.S. Army Corps of Engineers, Sacramento District. 42. "A Preliminary Assessment of Three Forks of the Stanislaus River for White Water Boating," Novenber 1971, Hammond, Childress and Anderson, Winters, California. (Consultant report to Sacramento District, CE.)

43. Letter to Sacramento District, CE, from the Yokut Wilderness Group of the Sierra Club, 3 July 1971.

44. "Fish and Wildlife Requirements in Relation to Water Development in the Sacramento-San Joaquin Estuary," by Harold K. Chadwick, Water Resources Engineering Educational Series, San Francisco Bay-Delta water quality.

45. Letter to Sacramento District, CE, from Bureau of Sport Fisheries and Wildlife, 25 January 1971.

46. Memorandum to Regional Director, U.S. Bureau of Reclamation, Region 2, Sacramento, California, on the East Side Division Central Valley Project, 12 December 1969, from Federal Water Pollution Control Administration.

47. "A Preliminary Study of the Effects of Water Circulation in the San Francisco Bay Estuary," 1970, Geological Survey Circular 637-A, B.

48. "Effects of the San Joaquin Master Drain," August 1968, Federal Water Pollution Control Administration, Southwest Region, San Francisco, California.

49. "Sonora-Keystone Unit, Central Valley Project, Water Quality Control Study," December 1970, report of the Environmental Protection Agency.

50. "Influence of Reservoir Discharge Location on Water Quality, Biology, and Sport Fisheries of Reservoirs and Tailwaters." Interim Report 1966-1970: C.E. Contract No. DACW 31-67-C-0083, October 1970, Sport Fishing Institute, Washington, D. C.

51. "The New Melones Archeological Project," a preliminary report, August 1970, by the Central California Archeological Society.

52. "Induced Hypolimnion Aeration for Water Quality Improvement of Power Releases," October 1970, Robert S. Kerr Research Center, Environmental Protection Agency.

53. "Downstream Temperature Study, New Melones Lake Project, Stanislaus River," November 1971, Office Report, U.S. Army Corps of Engineers, Sacramento District.

54. "An Approach to Reservoir Temperature Analysis," Technical Report No. 21, by Hydraulic Engineering Center, U.S. Army Corps of Engineers, Sacramento District. 55. "Reservoir Temperature Stratification," September 1969, HEC Computer Program No. 73-X2-L2810, Corps of Engineers, Sacramento District.

56. "United States Code, Annotated Title 33, Navigation and Navigable Waters, Section 701C.

57. Letter to Sacramento District, CE, 29 January 1971, regarding fish and wildlife management areas, from U.S. Bureau of Sport Fisheries and Wildlife.

58. Letter to Sacramento District, CE, 30 July 1964, regarding land acquisition for fish and wildlife enhancement. U.S. Bureau of Sport Fisheries and Wildlife.

59. "Vegetation Management on Reservoir Recreation Sites, Summary Report 1966-1971," July 1971, Department of Environmental Horticulture, University of California, Davis.

60. Subdivision Ordinance - Ordinance No. 527, Calaveras County and Subdivision Ordinance - Ordinance No. 170, Tuolumne County.

61. Joint Policies of the Departments of the Interior and of the Army Relative to Reservoir Project Lands, Federal Register, Volume 27, page 1734, 22 February 1962.

62. "New Melones Lake Project Secondary Effects," 10 April 1972, student intern report, Sacramento District, CE.

63. Civil Works Construction Guide Specification for Environmental Protection, CE 1300, May 1970, U.S. Army Corps of Engineers.

64. Weeds, Trees and Turf, February 1972, Volume II, No. 2, Harvest Publishing Co., Cleveland, Ohio.

65. "Delta Water Rights Decision, Decision 1379," July 1971, State Water Resources Control Board.

66. "Regional Resource Use For Agricultural Production in California, 1961-65 and 1980," September 1970, Shumway, King, Carter, and Dean, Giannini Foundation Monograph No. 25.

67. "Projection of California Agriculture to 1980 and 2000; Potential Impact of San Joaquin Valley West Side Development," September 1970, Dean and King, Giannini Foundation Report No. 312.

68. Letter to Stanislaus County Board of Supervisors from the U.S. Bureau of Reclamation, 28 October 1971. 69. "Policies, Standards and Procedures on the Formulating, Evaluation and Review for Use and Development of Water and Land Resources," 4 June 1964, U.S. Congress Supplement to Senate Document No. 97, 87th Congress, 2nd Session. NEW MELONES LAKE ENVIRONMENTAL IMPACT STATEMENT

APPENDIX C

DESCRIPTION OF CENTRAL VALLEY PROJECT, CALIFORNIA

U. S. Array Engineer District Corps of Engineers Sacramento, California DESCRIPTION OF CENTRAL VALLEY PROJECT, CALIFORNIA

Following is a description of the Central Valley Project in California, administered by the Bureau of Reclamation, U. S. Department of the Interior.

The Central Valley Project was Federally authorized for construction in 1935 under provisions of the Emergency Relief Act and as a Federal reclama­ tion project in 1937. In 1967 the project celebrated its twenty-fifth anniversary of providing water service via the , an initial unit of the Delta Division. This project marked the beginning of a new phase of water development in the Central Valley, as development in various parts of the Valley has been largely independent of each other prior to its initia­ tion. However, use of water had reached a stage where any additional facility in one part of the Valley affected existing and possible future development else­ where. Hence the need for a truly corprehensive and fully coordinated interbasin development program was recognized and undertaken through construction of the Federal Central Valley Project.

Major reservoirs of the Central Valley Project corpleted or under construction include Lake Shasta on the Sacramento River, Folsom Lake and Auburn Reservoir on the American River, on the San Joaquin River, and New Melones Reservoir on the Stanislaus River. Major aqueduct systems serving agriculture and industry in the Valley are the Delta- Mendota Canal, Friant-Kern Canal, , Contra Costa Canal, Folsom South Canal, Tehama-Colusa Canal and the Coming Canal. Other key features of the Central Valley Project are the San Felipe Division, Trinity Division, and the San Luis Division. The latter consists of in western Merced County and the San Luis Canal, which are joint features with the California State Water Project. The total cost of the Central Valley Project to date, including constructed and authorized features, is on the order of $2.6 billion. These major facilities are shown on Figure 38.

(1) Extracted from Bulletin 160-70, State of California, Department of Water Resources, "Water For California, The California Water Plan, Outlook in 1970." Current annual water deliveries under the Central Valley Project total some 6 million acre-feet. By about 1990 project water deliveries are anticipated to be some 10.7 million acre-feet to meet the increasing demands for new and supple­ mental water supplies within the service areas of the Central Valley Project. These annual demands are projected to grow by an additional 2 million acre-feet between 1990 and 2020. Authorization and construction of additional Central Valley Project facilities, principally the East Side Division and the West Sacramento Canals Unit, would be needed to provide this increase in water deliveries.

While the initial features of the Central Valley Project have been virtually coirpleted and other facilities have been authorized and are under con­ struction, the project is nevertheless anticipated to continue to evolve over the next quarter century to meet the demands within its service areas on an orderly and timely schedule. Priority additions include extension of the project's transportation systems— namely, the East Side Division Aqueduct System and the West Sacramento Canals, and the joint Federal-State Peripheral Canal.

NEW MELONES LAKE ENVIRONMENTAL IMPACT STATEMENT

ATTACHMENT A

PHOTOGRAPHS

NEW MELONES LAKE ENVIRONMENTAL IMPACT STATEMENT

ATTACHMENT B

CHARTS

NEW MELONES LAKE ENVIRONMENTAL IMPACT STATEMENT

ATTACHMENT C

CORRESPONDENCE RECEIVED

(Environmental Protection Agency U. S. Department of Interior U. S. Forest Service Soil Conservation Service Department of Commerce

Calaveras County South San Joaquin and Oakdale Irrigation Districts City of Modesto Environmental Defense Fund Sierra Club - National office Sierra Club - Yokut Wilderness Group Audihcn Society National Speleological Society Wildlife Society American River Touring Association Wilderness World

State of California) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY R EG IO N IX lOO CALIFORNIA STREET SAN FRANCISCO. CALIFORNIA 94111

FEB 2 5 1972

Department of the Army Sacramento District Corps of Engineers 650 Capitol Mall Sacramento CA 95814

Dear Sir: ~ J~‘-; We are replying to your letter of January 10, 1972 requesting our review and comment on the draft environmental statement for the New Melones Project, Stanislaus River, California.

The impact of this project on the environment is an important concern; however, appropriate considerations have not been fully covered in the statement. Specific comments are enclosed.

We believe, if you consider these comments in revising the text of your statement, it will result in a more complete and meaningful evaluation of the project's environmental impact. We would appreciate receiving a copy of your final statement. Sincerely,

Regional Administrator

. Enclosure ENVIRONMENTAL PROTECTION AGENCY REGION IX

Review and comment of the draft Environmental Impact Statement prepared by the Army Corps of Engineers for the New Melones' Lake Project, Stanislaus River, California.

The use of the 325,000 acre feet of potential irrigation water is a source of major controversy surrounding the New Melones Lake project. Since it is not yet certain where this water will be used, it is not clear that the agricultural runoff will be low in salt content. The salinity of agricultural runoff depends on the salinity of the soil and the salinity of the water used for irrigation. For example, high salt soil in the Coachella Valley is a major cause of the serious salinity problems of the Salton Sea. The impact statement should discuss the soil quality of the probable irrigation sites to support the comment that agricultural runoff will not be a significant environmental impact. As stated in Section V - Alternatives, on page 81 under Alter­ natives to the planned operation: " . . . the new water yield from New Melones could be utilized for releases to the Delta to meet recently established objectives of the California Water Resources Control Board in their Decision 1379 dated July 1971 which set forth minimum Delta flow requirements for the purpose of maintaining environmental quality in the Delta."

However, discussion of an operation schedule designed to help meet the requirements of Decision 1379 was not included, nor was information provided on the amount of water from New Melones that will actually flow through the Delta as part of the 1.6 million acre/feet requirement of the Decision. With the inclusion of this information in the impact statement, the implications of this alternative can be further evaluated. United States Department of the Interior

OFFICE OF THE SECRETARY WASHINGTON, D.C. 20240 APR 12 1972

Dear Colonel Donovan:

This is in response to your letter of January 10, 1 972, requesting the reviev and comment of agencies of this Department on the draft environmental statement for the New Melones Project, Stanislaus River, California, dated December 1971*

The authorized New Melones Project involves construction of a 625-foot high multipurpose dam and related appurtenances on the Stanislaus River, California, about 60 miles upstream from the confluence with the San Joaquin River. The New Melones Lake will have a surface area of about 1 2 , 5 0 0 acres. Project purposes are irrigation, flood control, hydroelectric power, recreation, reservoir and downstream fisheries and water quality control. Upon completion, the project will be operated by the Bureau of Reclamation as part of the Central Valley Project.

We are pleased with the coordination achieved between agencies of this Department and the Corps of Engineers during the planning and design stages of the New Melones Project. We would have preferred similar coordination during the preparation of the draft environmental statement.

The New Melones Project will destroy an area now having increasingly heavy recreational use because of the high-quality Whitewater boating opportunities.

A number of caves and archaeological sites will be inundated and wildlife populations will be adversely affected.

Throughout the December 1 9 7 1 draft environmental statement, reference is made that the New Melones Project will yield 3 2 5 , 0 0 0 acre-feet of water annually. Our best estimate for the past several years is 2 8 5 , 0 0 0 acre-feet annually. It is important to note that our reduced figure does not include any yield for water quality releases. Therefore, our figure must be further reduced. This apparent discrepancy needs clarification in the final environmental statement as the estimated amount of water available annually and its use are the bases for Obsessing environmental impacts. We believe the annual water yield should be considered a conservation yield rather than simply irrigation since a portion will be used for municipal and industrial purposes. Under the discussion of Project Purposes, pages 3-5, we believe it desirable for the final environmental statement to recognize that the Secretary of the Interior will be responsible for determining the quantity of water required to satisfy anticipated future consumptive water uses within the basin before exportation of any water made available by the New Melones Project. It is not necessary that the East Side Division be completed as there are now Central Valley Project irrigation service areas in which any available waters can be used effectively on an interim basis.

Although considerable attention is given to describing adverse impacts and potential means to mitigate such impacts, we are concerned that serious attention will not be given to unresolved problems. For example, the statement in the Summary and on page 1 that,

"The construction contract for the dam and spillway is scheduled to be awarded about 1 June 1972, if adequate funds are available.", and on page 8 1 that,

"If the alternative of no action were decided upon at this time, the investment of about $20 million which has been committed in construction of the New Melones project would be forfeited.", are not conducive to adequate discussion of environmental impacts.

We believe the December 1971 draft is inadequate in several aspects which need discussion in the final statement.

Only passing and scattered reference to minerals in the project area has been made. The authorized New Melones Reservoir will flood a substantial portion of the Mother Lode area which was the site of the California gold rush of 1849 and 1850. The Bureau of Mines originally reviewed the project in 196 2 . At that time it was concluded that overall benefits of the project justified foregoing additional mineral development. Essentially this position still appears valid. However, the draft environmental statement does not adequately consider potential loss of mineral resources as an irreversible and irretrievable commitment to the project. This is especially pertinent in view of recent increases in world gold prices and greater awareness of impending mineral shortages.

The project boundaries include 16 mines with significant past mineral production. Over 40 mines are within 1 mile of the project boundary where a full reservoir would present flooding hazard for present and future underground workings. It is further emphasized that active mining of this area stopped in 1 9 4 2 because of War Production Order L-208 and not because of exhausted ore reserves. The project area has been expanded since 1962 and now appears to contain two chromite mines and one asbestos mine which have been productive. Chromite is a strategic and critical commodity. If these mines are within the project boundary, the final environmental statement should discuss how underground mineral extraction would or would not be compatible with the intended use of the surface area for wildlife purposes. It is our opinion that the New Melones Froject will cause irretrievable losses of potentially workable mineral deposits. The final environmental statement should reflect this aspect. Enclosed are a sketch map and discussion of the affected mineral resources.

The draft statement does not discuss impacts associated with transmission lines required to distribute the power generated at the New Melones Project.

Soil and geologic structures in Tuolumne and Calaveras Counties are such that adequate garbage and sewage disposal are difficult. The final statement would be improved with an expanded discussion of how these problems will be solved for permanent habitations and related support facilities required for project operations personnel and for the expected influx of people seeking recreation opportunities. In the same context, are local community services, e.g., schools, police and fire protection adequate to meet the needs of the expected project work force?

While the draft environmental statement gives considerable attention to significant recreation, wildlife and fishery values, the draft environmental statement does not describe net impacts. For instance, on page 40, the statement is made that, "The problem of finding a reasonable method for mitigating for Whitewater (recreation use) has received considerable study and will continue to be investigated. Several approaches are being investigated...." On pages 26, 2 7 and 75# reference is made to caves having possibility of national or statewide significance, yet the draft statement does not identify whether the caves adversely affected have any significance, nor are any mitigative or protective measures recommended.

The discussion of the Bostick Mountain area (page 6) is misleading in that the State of California and the Bureau of Sport Fisheries and Wildlife have not yet determined its wildlife management potential. Of a more technical nature, we prefer the word "mitigate" wildlife losses rather than "offset" wildlife losses (pages 6 1 -6 2 ).

We also understand that the damaging effects of blocks of oxygen- deficient water extends downstream a considerable distance below Ripon. The final environmental statement should consider this, as well as the effect on the fishery should the concentration of oxygen fall below the 85 percent saturation median during critical stages of the life cycle of fishes inhabiting the Stanislaus River downstream from the New Melones Project. The attractive appearance of Bermuda grass in the unsightly reservoir drawdown zone is important. However, this grass has questionable wildlife value. We believe some other plant could meet the aesthetic needs and better meet wildlife and fish requirements. We also wonder if it would be possible to use vegetation removed from the reservoir site for mulch rather than burning as proposed on page 6 9 . The Bureau of Sport Fisheries and Wildlife would be happy to cooperate with the Corps in considering this aspect of the project.

The draft environmental statement touches only lightly on potential impacts on the Delta. This is a significant item and should be expanded in the final statement including anticipated diversions and return flows under project conditions and particularly impacts on the fishery, water quality and recreation during drier water years.

The discussion of alternatives would be improved if the final statement considers provision of recreation facilities together with improved public access to the existing Melones Reservoir. Also we are aware of estimates as high as 40,000 people running the Whitewater rapids to be inundated by the New Melones Reservoir and that this type of recreation use is increasing rapidly. We, therefore, suggest that accurate use and an estimate of projected use be sought and included.

The final environmental statement needs a better analysis of short- and long-term uses of the environment and the maintenance and enhancement of long-term productivity. Discussions pertaining to irrigation and municipal and industrial water use should be coordinated with the Bureau of Reclamation.

Page 6l infers that 100,000 acres of new irrigated land will be brought into production. Since water from the New Melones Project is intended primarily to replace ground water supplied now being overmined, it is unlikely that there will be any significant amount of new irrigation. This aspect should be clarified in the final statement.

We understand that your office as recently as March 9, 1972, has been conducting meetings with local residents and officials to resolve these important environmental matters. Until ultimate adverse environmental impacts of the project are more fully defined, constructive comments can be only speculative. We believe the final statement needs careful elaboration on these points. Agencies of this Department stand ready to assist in that endeavor.

S inc er elyyf'ours.

9puty Assistant ^ / Secretary of the Interior

Colonel James C. Donovan District Engineer, Sacramento District U.S. Army Corps of Engineers 650 Capitol Mall Sacramento, California 95814

Enclosures 2 United States Departm ent of Agriculture FOREST SERVICE

. 2lUo ■ February 25, 1972

Colonel James C. Donovan Department, of the Army Sacramento District, Corps of Engineers 850 Capitol Mall ^Sacramento, California 958lU

Dear Colonel Donovan:

In response to your letter of January 10, 1972, we are glad to have the opportunity to review your draft environmental statement for Melones reservoir. Although the reservoir lies Just outside the Stanislaus National Forest, most of the watershed is on National Forest lands. We have closely checked the influence this project may have on game and fisheries, and are acutely aware of the effect Forest management may have on water quality.

Our comments follow:

1. The statement appears somewhat weak in proposing positive measures, programs, and acceptance to assure minimum adverse environmental impacts, for example see page 55-56. Areas could be developed to improve wildlife food conditions to help over­ come wildlife losses. People could be restricted from some areas including possibly some of those shown for recreation development. Sub-impound­ ments could be constructed within the reservoir for fisheries and wildlife.

2. Page 7 6 , Scenic Value Losses - "... drawdown will create unattractive belts of non-vegetated land... Such zones are typical at all multi-purpose and irrigation reservoirs." The question here is... need they remain so? Perhaps some development could enhance this eyesore.

3. We have found no effect on the migration of game animals from National Forests within the influence zone of the reservoir. U. In order to assure that the water flowing into the reservoir from National Forests is of usuahle quality the overall policy (Forest Service Manual 25^3.03) of the Forest Service requires that ”... National Forest land management practices are conducted in a manner which will ensure a quality water yield suitable for its intended purpose." Also, "... The Forest Service will cooperate with the Department of Health, Education, and Welfare and with States, counties, and municipalities having jurisdiction over water for the purpose of ensuring safe supplies for domestic and recreation use and preventing and controlling water pollution from waste disposal."

5• Fisheries

a. It is indicated that certain fisheries studies pertaining to the project are underway and their results not yet available. We assume some "open end" arrangement is made to encorporate these findings into the Environmental Statement when they are completed.

b. What assurance will be given that the minimum flows released for fishlife will be utilized for that purpose in perpetuity and will not be subject to appropriation for other uses? If they are encorporated as beneficial aspects of the cost-benefit ratio, we assume that they have some degree of permanence.

c. One of the major problems developing from such water developments is the provision of fisheries enhancement in downstream river stretches without adequate provision for public access to such areas. It is suggested that public access provisions be assured in the case of the Stanislaus River Designated Floodway.

d. Are there benefits to be obtained from providing for multiple release outlets at various elevations of the new reservoir? This may warrant investigation in relation to desired temperature regimes. e. The matter of screening of diversion intakes and reservoir outlets'''is suggested for inclusion in your analysis.,.,

f. The proposed "dry cycle" definition would seem to be more appropriately related to the runoff pattern of the river system under development rather than related to water deficiencies in the overall Central Valley System.

Other than the above comments, we found the report to be well prepared and giving good coverage. We are returning one copy of the Draft Environmental Statement.

V • n • * w w i a .a Acting Regional Forester

Enclosure UNITED STATES DEPARTMENT OF AGRICULTURE SOIL CONSERVATION SERVICE 2020 Milvia Street, Berkeley, California 94704

Your Reference: SPKED-P February 22, 1972

Colonel James C. Donovan District Engineer Corps of Engineers 650 Capitol Mall Sacramento, California 95814

Dear Colonel Donovan:

Your draft environmental impact statement concerning New Melones Lake, Stanislaus River, California, prepared by the U. S. Army Engineer District, Sacramento, California, has been reviewed in this office. Your report indicates that, overall, a completed project as described would have greater beneficial environmental impacts than adverse environ­ mental impacts.

Activities of the Soil Conservation Service in the project area at this point in time will not impact to any remarkable degree upon the proposed New Melones Lake.

Please refer to pages 69 and 70 in your statement where you have described, in a general sense, management of disturbed earth, vegetation, and other materials during and after construction. We assume that there will be definite planning and action to keep sediment out of the lake area and especially out of the tributaries and the Stanislaus River during and immediately after construction. We have in mind that sprinkling, shaping or grading, revegetation and all other related activities that would mitigate the rapid movement of sediment from freshly disturbed earth areas into the waterways. Revegetation for wildlife habitat is highly essential in a beneficial sense.

We are pleased to note that you have given consideration to recreation facilities, pertinent roads, and parking areas so as to minimize environ­ mental disturbance.

For soil and water conservation information concerning the project area, we recommend that you contact Austin D. Warnken, Area Conservationist, Soil Conservation Service, 650 Capitol Mall, Room 3400, Sacramento, California 95814, Phone: FTS (916) 449-2403/2141.

We are glad to offer comments.

Sincerely,

T. P. HELSETH State Conservationist cc: Kenneth E. Grant, Adm., SCS, Wash., DC w/copy of environmental statement Austin D. Warnken, SCS, Sacramento, CA w/o copy of environmental statement OFFICE OF THE ASSISTANT SECRETARY OF COMMERCE Washington, D.C. 20230

March 10, 1972

Colonel James C. Donovan District Engineer Department of the Army 650 Capitol Mall Sacramento, California 95814

Dear Colonel Donovan:

The draft environmental impact statement titled "New Melones Lake, Stanislaus River, California," which accompanied your letter of January 10, 1972, has been received by the Depart­ ment of Commerce for review and comment.

The Department of Commerce has reviewed the draft environmental statement and has the following comments to offer for your consideration.

In general, the Environmental Impact Statement (EIS) covers most of the complex environmental problems associated with the New Melones Dam and Reservoir development. However, the following points may merit discussion:

There is a distinct possibility that adverse environmental effects will occur with the increased use of project water for agricultural, urban, and industrial development. This point, lightly considered on page 50, might warrant further consideration.

The anticipated increase of a resident warm-water fishery noted on page 57 would be in direct competition with the anticipated increase of anadromous fish runs. This competi­ tion would be for space and food. In addition, there would be considerable predation on immature anadromous fish species by the warm-water species. These points may be worthy of more extensive treatment.

We hope these comments will be of assistance to you.

Sincerely,

Sidney Galler Deputy Assistant Secretary for Environmental Affairs CAI-AVKRAS COUNTY BOARD OF SUPERVISORS

GOVERNMENT CENTER SAN ANDREAS, CALIFORNIA 95249

February 28, 1972

U. S. Army Corp of Engineers 650 Capitol Mall Sacramento, California 95814

Bureau of Reclamation 2800 Cottage Way Sacramento, California

Gentlemen:

The Calaveras County Board of Supervisors has received the Environ­ mental Impact Statement (draft) dated December 1971 as prepared by U.S. Army Engineer District, Sacramento, California.

The Board of Supervisors basically has no objections to the statement and conditions set forth in the Invironmental Impact but wishes to comment on certain specific areas.

Throughout the Environmental Impact Statement, there are references made to recreational development and subdivision development. With this type of development taking place it will naturally be an in­ creased burden on County services. We are requesting a continued effort in liaison with the different Federal Agencies in dealing with this development.

The Calaveras County Board of Supervisors would like to further state that it wishes to cooperate in all matters pertaining to the New Melones Project.

Very truly yours,

ERNEST F. BERNASCONI, CHAIRMAN CALAVERAS COUNTY BOARD OF SUPERVISORS TRI-DAM PROJECT OP THE SOUTH SAN JOAQUIN AND OAKDALE IRRIGATION DISTRICTS

□ STAR ROUTE BOX ISOS. SONORA. CALIF. S937C PHONE (SO S> B6S-32I4 (9 P. O. BOX 1SS. OAKDALE. CALIFORNIA 80361 PHONE (SOS> B47-OS4S

February 28, 1972

Col. James C. Donovan District Engineer Department of the Army Corps of Engineers 650 Capitol Mall Sacramento, California 95814

Dear Col. Donovan:

The Oakdale and South San Joaquin Irrigation Districts appreciate the opportunity to comment on the Draft Environ­ mental Impact Statement for New Melones Dam.

We note with considerable concern that the Environmental Impact Statement is silent with respect to the impact New Melones Project will have on Tulloch Reservoir. We believe that this impact will be substantial and should be thoroughly discussed in the Environmental Impact Statement, including consideration of the following specific elements:

1. Visual impact: In providing reregulation of peak water releases from New Melones Power Plant, we have been advised by the Bureau of Reclamation that the water surface elevation in Tulloch Reservoir will fluctuate between elevation 500 and elevation 510 with a maximum cycle of three or four days. Such fluctuation would expose an unsightly band of mud and rock below the high water line of the reservoir during most of the peak public-use season, a condition which the Districts have attempted to avoid except during periods of critical runoff deficiency.

2. Recreational impact: Peak water releases from New Melones Power Plant, which we understand will reach 8,300 c.f.s., could create potentially hazardous currents in the portion of Tulloch Reservoir upstream Col. James C. Donovan Page 2 District Engineer Department of the Army Corps of Engineers February 28, 1972

from the O'Byrnes Ferry Bridge and further could cause the water surface elevation in Tulloch Reservoir to rise at a rate in excess of 7 inches per hour, both of which effects we believe would be detrimental to the recreational features of Tulloch Reservoir, which are presently enjoyed by thousands of people annually. The anticipated short-term fluctuations in water surface elevation would also increase the cost of installing and maintaining boat docking and servicing facilities on Tulloch Reservoir.

3. Economic Impact: The 10,000 to 20,000 acre feet of storage space in Tulloch Reservoir that will be used by the United States for flood control and reregulation will reduce the head available for Tulloch Power Plant and will thereby prevent the Districts from releasing their full irrigation water supply through the power plant. It will be necessary to release a portion of the water through the spillway or bypass valves without the generation of power. Not only will this increase the cost of operating and maintaining the spillway and bypass facilities, but it will also reduce the Districts' power generating capabilities at Tulloch Power Plant by as much as 20%, and may thereby prevent the Districts from fulfilling their contractual obligations to deliver power to Pacific Gas and Electric Company.

We feel consideration should also be given to the impact of New Melones Project on Woodward Reservoir. Woodward Reservoir is owned by the South San Joaquin Irrigation District and the shore area is operated by Stanislaus County as a recreational facility presently providing in excess of 300,000 visitor days of recreational use per year. Woodward Reservoir is presently filled during the winter months by diverting water that would otherwise be wasted down the Stanislaus River. It is kept full and evaporation and seepage losses are satisfied out of the South San Joaquin Irrigation District's share of the water supply available under the Districts' joint water rights. The Stanislaus County Parks and Recreation Department has determined that 20,000 acre feet is the minimum storage in Woodward Reservoir that would support present recreational use. Under current proposals of the Bureau of Reclamation for furnishing water to the Oakdale and South San Joaquin Irri­ gation Districts out of New Melones Reservoir, the strict Col. James C. Donovan Page 3 District Engineer Department of the Army Corps of Engineers February 28, 1972

limitation on the quantity of water the Districts could divert would make it necessary for the South San Joaquin Irrigation District, in many years, to reduce the amount of water stored in Woodward Reservoir to a minimum level below 20,000 acre feet in order to reduce evaporation and seepage losses. We therefore assert that the operation of New Melones Project, as presently proposed, will significantly impair the recreational use of Woodward Reservoir.

The Draft Environmental Impact Statement devotes considerable attention of the matter of white-water boating. We seriously question the suitability of a reach of the Middle Fork Stanislaus River above Stanislaus Power Plant for mitigating the loss of the present white-water boating area. The average stream gradient above Stanislaus Power Plant is more than twice the average stream gradient below it, making that reach much more hazardous than the reach that will be inundated by New Melones Reservoir. In addition, we believe a substantial flow of water would be required to support white-water boating above Stanislaus Power Plant. Except for the normal spill period during the late spring and early summer, such water would have to be released from storage upstream and could not be used to generate power at Stanislaus Power Plant. Because of the tremendous value of that falling water for power generation purposes, we believe that the cost to the United States of making it available for white-water boating would be prohibitive. In addition to the cost of the stored water, other extra costs would be associated with the operation of Beardsley Dam, Beardsley Afterbay Dam and Sandbar Dam in regulating releases for that purpose.

The Draft Environmental Impact Statement also refers to potential white-water boating between Goodwin Dam and the Knights Ferry Bridge. We wish to point out that most of that particular reach of the Stanislaus River is bounded on both sides by canals of the Oakdale and South San Joaquin Irrigation Districts. Because of the inherent hazards associated with these deep, swift-flowing canals, the Districts do not encourage public use of that reach of the river and are not willing to accept any liability associated with the provision of public access to the Stanislaus River in the vicinity of Goodwin Diversion Dam.

The negative character of the preceding comments is not indicative of the Districts' response to the Draft Col. James C. Donovan Page 4 District Engineer Department of the Army Corps of Engineers February 28, 1972

Environmental Impact Statement as a whole, but pertains only to those points specifically noted. In other respects, the report appears to us to adequately identify and discuss the potential effects of New Melones Project on the environ­ ment in which it is being constructed. It is obvious that a great deal of time and effort has been devoted to it.

If you have any questions concerning the comments stated above, please do not hestiate to contact me.

Very truly yours,

OAKDALE and SOUTH SAN JOAQUIN Il?RIGATfq^d5lSTRICTS

/Keith F. Chrisman, Executive Secretary for Tri-Dam Project CITY OF MODESTO CALIFORNIA

City Hall, 801 Eleventh PARKS AND RECREATION DEPARTMENT P. O. Box 642, 95353 (209) 524-4011

May 8, 1972

Colonel James C. Donovan District Engineer U. S. Army Corps of Engineers 650 Capitol Mall Sacramento, California

Dear Colonel Donovan:

I have been discussing your New Melones Project Environmental Impact Report with a number of people interested in that project, as well as projects along Dry Creek and Tuolumne River in the Modesto urban area. Dry Creek in Stanislaus County flows from the foothill area between New Melones and Don Pedro Reservoirs to the center of Modesto where it empties into Tuolumne River. City parks are being planned along Dry Creek for a distance of approximately five miles and along Tuolumne River for a distance of approximately seven miles. Hiese two regional parks will also include a park area at the confluence of Dry Creek and Tuolumne River. We estimate that countless numbers of people will use these tree-shaded urban parks daily.

Dry Creek is highly polluted with dairy wastes at the present time, which are being removed with help from the State Water Resources Control Board, Stanislaus County, and the Agricultural Stabilization and Conservation Service. I understand the Corps also is interested in this program under provisions of the 1899 Refuse Act.

It has been brought to my attention that your division may recommend using New Melones water to improve water quality in the lower Stanislaus River, the San Joaquin River and the Delta, and we think that is a good idea. We also understand a flow in the lower Stanislaus exceeding 600 cubic feet per second is not recommended for canoeing and other boating recreation, and hope you will consider that in your final decision. Colonel James C. Donovan May 8, 1972 Page 2

Perhaps a small amount of New Melones water could be introduced into the upper reaches of Dry Creek, either through facilities of the Oakdale Irrigation District, or with a new conveyance. Such a flow would help convert Dry Creek into a beautif ill waterway, particularly after the pollutants are removed as expected. The water would reach the Delta via the Tuolumne and San Joaquin Rivers.

I would be happy to discuss this idea with you or a representative of your agency, and hereby submit this letter as my comment on your Environmental Impact Report on the project.

Sincerely,

Mary E. “Grogan ( s Director of Parks and Recreation ENVIRONMENTAL DEFENSE FUND 27£8 DURANT AVENUE, BERKELEY, CALIFORNIA 94704/415 548-8906

t

February 2, 1972

i

Colonel James Donovan District Engineer Corps of Engineers 650 Capitol Mall Sacramento, California 9581^

Dear Colonel Donovan:

The following are the comments of the Environmental Defense Fund on the Draft Environmental Impact Statement (EIS) on the New Melones Project.

We are pleased to note that the Draft EIS is markedly Improved over the working paper. Several changes have been made which makes it clear that the Corps intends to consider several impacts which are not usually considered in a project of this type. However, the EIS has many shortcomings, and must still be considered inadequate.

First, we shall not repeat the comments made on the working paper. Some of these have been answered through personal communication, and some have been unanswered. We still hope for answers to those comments, to the questions in our previous letter, as well as answers to the comments in this communication.

I Our- principal objections to the project is still the fact that It will be operated as a unit of the proposed East Side Division when that unit is authorized. The additional irrigation the East Side Division would provide is not now needed by the people of the United States, and would actually prove detrimental to the agricultural industry both in California and the Nation. We believe that the EIS does not explore adequately the possibility of operating the project as a water supply facility for the San Francisco Bay-Delta environ­ ment. A second objection is that alternatives are not really- given fair consideration. The entire report is written under the supposition that the project will continue to be built as presently planned. Only scanty consideration is given to alternate possible operating methods.

Third, there are no guarantees even proposed that sub­ stantial mitigation will take place in the fields of white- water boating, downstream canoeing (the question of adequate flows for that part of the river is almost entirely ignored), fish and wildlife protection, and riparian habitat protection. Unless some sort of firm guarantees can be given that the Corps will at least formally request Congress to consider some sort of mitigation other than what is now planned, the EIS can only be considered to be a detached study, with no real promise that any of the problems discussed will really be dealt with.

The EIS should contain all of various studies described within it, including those of the flora and fauna, Whitewater boating, caves (NSS), fisheries, Kay and Meral, and others.

A serious fault of the working paper, carried into the Draft EIS is the lack of substantiation of the various claims made in the report. There are literally hundreds of assumptions and factual statements made about every phase of the project without any references given or sources quoted. The EIS should be a scientifically correct study, and as such should follow the rules of scientific writing. As it is now written, it is only a collection of allegations. However, it is an improvement over the working paper, since at least some references are given.

The problem of easements along the lower river is a very serious one. I understand that the Bureau of Sports Fisheries and Wildlife proposed that up to 3^00 acres be purchased by the Corps for riparian habitat protection. We concur although not necessarily with that exact figure. The EIS's statement that local control is the only practical method for protecting the riparian environment is false, as indicated by the figures on the destruction of the habitat in the last few years cited in the EIS.

The tables and figures in the EIS should be numbered and listed in the table of contents.

As was the problem in the working paper, the discussion is disjointed: almost every issue is discussed in a number of different ways in the various sections. This is especially true of the discussion of the alternative uses of the project yield (irrigation versus Delta protection), and Whitewater boating. The CEQ guidelines could be followed while still making the report shorter and more readable.

The EIS should be sent to the various political officials in the areas affected, including Congressmen Johnson, Sisk, McFall, Waldie, Mathias, Talcott, and perhaps the S.F. Bay Congressmen. Senators Tunney and Cranston should also receive the EIS. Since other local agencies are being consulted, so should the local Assemblymen and Senators. ,

We wish to call special attention to our comments on the allocation of water rights from the Stanislaus (EIS p. 5) and the earthquake hazard (EIS p. ^3).

With regard to mitigation for the whitewater boating section of the river, we note that the Corps has had little experience with this sort of problem. This is a new area generally, so we will be especially interested in how mitigation for this loss of a benefit will occur.

We once again raise the question of who will pay for re­ moval of the dam once its use is at an end. Even though the reservoir will be less than one percent silted in, the dam itself presumably has a limited lifetime. If the project life period is now 100 years, what will happen after that? This entire question is neglected, except for a brief mention under "adverse environmental effects."

We propose that the project be re-evaluated under the new Water Resources Council guidelines, including new interest rates, and new social, economic, and environmental consideration. This would give a better idea of what society now sees as the true value of the project. In addition, such a re-examination would make it possible to attempt to resolve the presently "unreconciled conflicts."

We object to the manner in which the co-ordination between the Bureau of Reclamation and the Corps of Engineers is being carried out. While the project is being built for the Bureau of Reclamation, the Corps is taking all of the responsibility of writing the Environmental Impact Statement. It thus becomes clear why there can be few or no guarantees about mitigation, since the Corps will have little responsibility in operating the project. Through conversations with the Bureau, we have learned that they still believe that the East Side Division is a viable project, and Intend to pres3 forward in Congress and elsewhere for its authorization. If this is the case, it is very unlikely that they are giving serious consideration to other alternatives. This means that all the work the Corps is doing on alternatives will probably be discarded by the Bureau, making the entire process of preparing the EIS some­ what futile.

To correct this situation we suggest that the Bureau become mere intimately involved in the planning process, and in the preparation of the EIS. For a start, the Bureau's comments on the Draft EIS should be immediately circulated to the other parties commenting on the EIS, so that their views will be more widely known. Second, the Bureau's evaluation of the need for water from the project in the East Side of the Valley and in the Delta should be included in the EIS. Finally, a statement of intent with respect to agreements the Corps makes with regard to operating the project is desirable. This would alleviate the impression that the Corps is simply acting as a shield for the Bureau, deflecting any criticism off'lproJect by dealing with the public, yet all the while stating that they do not have ultimate responsibility.

Finally, since a final Environmental Impact Statement is not complete, we request that all work on the project cease, and that no further contracts be put out for bid or accepted until the final EIS has been on file with the CEQ for 30 days.

We would appreciate an early response to our comments and requests. Thank you for your co-operation.

Yours very truly,

Gerald H. Meral Staff Scientist "DETAILED COMMENTS"

Page § title EIS should be on "project", not on "Lake". title Date: since we know of no mailing before Jan. 10, 1972, It should be dated no sooner than that.

3 4 It would be helpful to provide a sample expected schedule of releases for water quality. It is known when these releases would most likely be needed.

5 4 This is a slgnfleant section. In the last paragraph, the statement of the authorizing act mentions "needs within that basin." Dees the Corps take this to mean that the needs of Sacramento-San Joaquin Delta are included under the mentioned "needs"?

We would like to briefly discuss the Water Rights appropriation. First, the application (and permit) state that the power plant would be completed on or before 1970. This is not the case.

The Water Rights were applied for (and granted to) the Bureau of Reclamation. The permit specifically points out that the water is to be used in the East Side Division of the Central Valley Project (p. 3 "USE": "Upon completion fo the proposed East Side Division, the operation of the New MeloneJDam will be integrated with the Central Valley Pro­ ject".) Other information in the Water Rights application clearly indicate that the water is intended for use in the East Side Division.

9 10 There should be some definition of "extensive channelization".

9 11 This analysis of costs and benefits is inadequate. There should be at least some breakdown of what the costs and benefits are. In addition, the project should be examined in terms of the proposed new Water Resource Council guide­ lines on water projects. This would provide some perspective on how the project would fare if examined in light of the desires and needs of the United States in 1972. Page §

21 18 The estimate of 20,000 angler days in the river upstream of Melones Dam in now ten years old. Rising population, as well as increased popularity of river fishing would indicate that this figure should be increased to at least 30,000. In Meral's report on the Stanislaus River the figure used was 15,000 angler/days. This was an error.

The data on fishing below Ooodwin Dam, and in Tulloch and Melones reservoirs is similarly outdated.

22 20 The report mentioned (by Jones and Stokes) should be appended in its entirety. The discussion of endangered species is especially relevant.

29 25 We repeat our question about refuse act permits for the various mines near the river, especially the aspestos mine. A discussion of the recent problems with some of these mines should be included.

31 It should be pointed out that the Knight's Perry location is selected because of the proposed diversion of water from this point into the East Side Division. This was clearer in the working paper.

There is a typographical error in the table headings which read "five low months" instead of the previous "five lowest water years". The heading on the final table (p. 32 should be "five highest water years."

33 26 Included in this discussion should be the effect of a flood larger than the maximum one planned for. What will be the effect on agriculture, business, and homes which locate on the flood plain expecting total flood control?

While there may be low probability of dam failure due to earthquake or other causes, the effect would be so devastating (particularly if the reservoir were full) that the impact should be discussed. How many deaths would be expected, and how much property damage would probably occurT

33 26a What are the alternative means of protecting the 235,000 acres from floods? Page §

>34 26b It should be made clear that all the power generated by the project would be utilized by the East Side Division, should It be constructed, and that this Is the present Intention of the Bureau of Reclamation (“Economic Analysis Appendix, East Side Division, Central Valley Project, September, 1961" by USBR, Department of Interior.)

The environmental impact of this Increase In power generation should be discussed, in terms of what the power will be used for. In addition, there should be some discussion of the effect of new transmission lines.

35 26b There should be some discussion on the effect of diverting another 325#000 AP of water from the Delta, especially the effect during the critical summer months, and the effect ) on flushing of the Bay during the winter months. In addition, more discussion is needed of what happens to the Irrigation water once farmers are done with It: since it then becomes agricultural wastewater, it can have serious effects on water quality: this should be discussed both for the local area and for the ESD service area.

35 26b The reader should be referred to paragraph 91 which deals with the true value of new irrigation water, or that section should be incorporated into this one.

36 27a This section is inadequate. First, Mr. Kay's data for 1970 indicated that there were actually 9000 visitor days due to professional rafting. He Included 2000 visitor days due to tourism in the river area before and after the raft trip, in addition to the 7000 visitor days on the river itself. The total figure for 1971 should be shown, which was about 13,000 (final figure pending). The figure for fishing is from i960 or so, and should not be cited as "(1970)." A current figure, as mentioned above must be around 30,000. The table should thus appear as follows:

a c t i v i t y estimated recreation days annually (1971)

commercial raft trips 13 ,0 0 0 private rafting & kayaking 10 ,0 0 0 fishing on river 30,000 miscellaneous (gold mining, 15 ,0 0 0 h ik in g , e tc .) 68,000 G:iven the rate of increase of many of these activities, and the increased interest of the public in wilderness- oriented activities, it seems likely that the estimate of "60,000 recreation days annually by 1980" is far too low. A better estimate would be about 90,000 visitor days annually.

There should be some substantiation of the estimates of reservoir use. This could include statistics on use from opening day to present on other reservoirs in the area, such as New Hogan. In addition, some measure of the predictive ability of the Corps and other agencies in this field should be shown, such as the estimates versus actual use of such reservoirs.

More discussion is required on the use of the lower river. How much use does it get now, and how much would it be increased or decreased under various alternative management plans? This section should include use with and without operation of the East Side Division.

There is little or no discussion of the comparative values of the two resources: wild river versus reservoir. The qualities of the resources are obvioie ly not the same as discussed in many articles by Knetsch, Clawson, Leopold, and others. The new guidelines of the Water Resources Council point out that most reservoir oriented activities may be valued at $0.75 to $2 .2 5 per visitarjrday, while more specialized (such as river oriented) activities are valued at from $3 to $9 per visitory day.

43 29 In this section the geology of the area, especially that of the dam site should be discussed. It is surprising that the probability of major earthquakes is not discussed. The Bostick Mountain Fdft.t Zone (part of the Bear Mountain Fault) runs less than 1 0 0 0 feet downstream of the dam site, and the Melones Fault runs directly beneath the present Melones reservoir. In addition, this area was severely shaken by the Inyo earthquake of March 26, 1872, which would have read 8 .25 on the Richter scale. The studies done by the Corps on the geology of the area should be cited in this section.

NOAA offered to study the effect of the dam on earth­ quakes in the area, but the Corps refused the offer. The study would have cost about $ 7 5 , 0 0 0 , approximately 1 Page § 4 one-hundreths of one percent of the cost of the total project. Considering^he earthquake study was Important to the preservation of the lives of tens of thousands of people, it Is difficult to imagine that other more ex­ pensive mitigation facilities will be purchased and operated.

*J5 29a There is insufficient explanation of damage to the caves. The NSS report should be included as an appendix. How much will the cave operators lose, and will they be re­ imbursed for this taking? In what ways will the inundated caves be damaged?

*15 30 The discussion in the working paper on irrigating the soils of the East Side Division service area was in some ways superior: it was more detailed.

While it can not be denied that water quality is an authorized project purpose, it must be questioned whether this "toilet flushing" function of the reservoir can still be considered a benefit with regard to solving the pollution problems of the Stanislaus. It would seem far more pro­ ductive to propose methods by which the agricultural return flows Into the river could be treated. In addition, the Corps is indirectly responsible for many of the pollution problems on the Stanislaus, due to the total non-enforcement of the 1899 Refuse Act. Although Colonel Donovan has him­ self observed many violations of the Act (In a trip down the river), there has yet to be a permit granted for dis­ charge Into the river (to our knowledge), nor has there been any action to prosecute the many industries which discharge into the river.

The discussion of the high winter flows into the San Francisco Bay is inadequate. Indeed, it is implied that reduction of these flows would be a project benefit (30b). The USGS circular 637-A,B clearly implies that the high winter flows in the Bay are beneficial for flushing. While some augmentation for the summer period in the Delta is desirable, the main problem at that time is salinity in­ trusion and not pollution.

To what extent is there presently an anaerobic layer in Melones Reservoir? If the anaerobic layer Is greatly increased, is there a significantly Increased danger from methylation of mercury or other dangerous chemicals?

There should be some discussion of the effect of occasional very high flood flows. These prevent intrusion of willows on the riverbed, carry away debris which can accumulate on the banks, etc.

A discussion is needed of exactly when the water would have to be released for water quality under present con­ ditions to meet the D.O. criteria listed. Is the 70*000 AF/yr presently allowed sufficient? Under present design, can the criteria be met with released from the hypolimnion? Will the special works discussed be required, and when will the studies to determine this be completed? The final EIS should not be released until they are.

The discussion of the effects of irrigation on water quality is insufficient. To my knowledge the San Luis Drain is not presently under construction. The areas of potential irrigation must be pinpointed and carefully examined. The general statements about soil alkalinity could apply anywhere. Even so, it is clear that under present conditions in most areas there will be an overall detriment to water quality if the 325*000 AF of water are used for irrigation, insofar as they irrigate new lands, or more intensively irrigate present agricultural lands.

As is so often the case, a flat statement is made about an alteration in "natural waste assimilation capacity." Not only are no figures for this given at all, but neither is the direction of the change! This clearly means that the capacity will be reduced.

There should be an especially detailed discussion of the problem of wastewater returns which would enter the Stanislaus and the San Joaquin in the Vernalis area. If these are significant, the water quality benefits claimed by the project might be impossible to achieve.

47 Is it implied that roads are an improvement? This is a value Judgement, and not appropriate in this context.

47-9 There seems to be a conflict between the statements on page 47 and ^9 about the effect of anaerobic and other conditions on the downstream (and Tulloch) fisheries and water quality. Is it or is it not now known whether there will be an effect? Page §

^ 8 The PHS statenent Is now seven years old. EPA’s comments on the validity of using reservoirs to clean up stream pollution should be Included In the final statement. We believe that In most cases (including this one) man-made pollution should be cleaned up at the source, not diluted.

50 What Is the basis for saying that materials which enter the water under anaerobic conditions will leave the water under aerobic conditions? Will they leave via the biota to some extent?

50 Obviously one of the ways which future development could be controlled would be through purchase of easements along the lower river, and by extending the take line to prevent con­ » struction of homes within the reservoir area. This latter method is being used by the Bureau of Reclamation at Auburn Reservoir.

4 9 Proof of the statement that inundating new areas will not have an adverse effect on water quality is required. Occasioi rain erosion is not comparable to inundation, especially con­ sidering the difference in oxygen conditions.

50 No definitive statement is made that there will be no problem with supersaturation of nitrogen, nor is evidence offered.

58 31b This discussion is inadequate. There is no evidence at all presented here that there will not be significant harm to ) the spawning gravels, ^ut surely there must be some evidence from some rivers about what happens under such conditions.

59 31c It is good to hear that planning is going on. However, to proceed with a project while plans are still in such a pre­ liminary stage is contrary to sound planning and an invitatioi to disaster. If the project is completed before the plans are carried out, the Corps will leave the field, and the Bureau of Reclamation, operator of the disastrous Lake Berryessa, will become manager of the project, and the Corps will be relieved of all its obligations in the field of management.

It is my impression that the Pish and Wildlife Service has > 59 asked for purchase of, about 3200 acres above the reservoir, and about 3^00 acres along the flood channel. This would provide a drip from 200 to 500 feet wide on both banks all the way down the lower river, and would probably be adequate Page § ( in most places. The area along the flood channel is vital not only for wildlife habitat, but also for aesthetic pur­ poses. This area will of course be especially endangered by agricultural encroachment when flood protection is guaranteed.

In addition, for any downstream angling benefits to occur, more public access will be necessary. It is stated that the public can only gain access to the river along 10# of its length. This two to four miles will obviously not be sufficient to permit the benefits described, nor will it be possible to protect spawning gravels.

51 There is insufficient discussion of the impact of second , home and commercial development around the reservoir. The \ effects on water quality could be notable. Some discussion of similar problems at other reservoirs would be appropriate.

52 While it may be quite late, it is appropriate to ask whether a Refuse Act permit has been issued. Issuing the permit to the Corps would permit EPA to comment more directly on the dam construction process.

52 31a Obviously a wild river fishing experience will be lost. How is this compared to the increasingly common reservoir fishing experience?

52 31a What sort of fish can be expected in the warm water fishery? (

50 31a The objectives for the downstream fishery should be made much more clear. What was the condition of the stream before man intruded with either dams or agriculture? Is it the goal of the Corps to regain those conditions? Or does the Corps intend to go beyond them, to increase the number of fish which use the river, or to change the species composition? Just because present conditions are deplorable, it is not clear that it is necessary to construct a giant dam to improve them. What would wastewater treatment accomplish, accompanied with altering the release regime from Tulloch, or perhaps accompanied by a smaller Melones or enlarged Tulloch?

5*J 31a "Unacceptable to fish" implies certain species under certain conditions. More detail is needed. Were conditions before man arrived on the scene "unacceptable?" Page § l ■ 5*1-5 How frequently would specified temperature ranges have been exceeded if there had not been an historic drought period: there should be a number following each number in the table marked with an asterisk which shows the number of days which occurred in the historic dry years.

56 31b There will be little or no free-flowing river between Knight’s Perry and Goodwin Dam if the Knight’s Perry Reservoir is built. This would wipe out most of the proposed trout fishery.

62 32b It is deceptive to list a supposed benefit in one place (for irrigation) and not list any of the costs either here or elsewhere. A discussion listing all costs and benefits 1 should be given all in one place.

63 32c This is incorrect. The only practical method of avoiding adverse effects outside the flood limits is direct acquisition of some of the riparian habitat, along with local control. To the extent that adverse impact is expected, acquisition should take place, along with speedy public notice to the citizens of the counties.

6 1 -3 32 There should be some estimate of the additional costs of the project, such as increased policing, the cost to the public of removal of public lands, and so on. No project costs are allocated to the removal of public lands in the various reports to Congress. Is the land worthless?

57 Paragraph 26, not 28, is devoted to hydrology.

6*1 32 What is the exact status of the Stanislaus River Designated Ploodway? What will be required for the Reclamation Board to approve it?

6*1-7 33 The whole discussion of wildlife is almost esoteric. There is little mention of actual species, and no estimates of populations given. A wide variety of alternatives are named, while no assurances are given that any will actually be im­ plemented. The only thing obvious from the discussion is that there will be a major loss of wildlife habitat, especially of riparian habitat, with almost no mitigation except in one area of less than 2200 acres. There is now almost no guarantee of any mitigation of loss of wildlife. Especially objectionable in the discussion is the mention of the "edge effect", not widely known from fluctuating reservoirs, the proposed "chemical treatment" of chapparal areas, and the statement that "grassland is not a limiting factor due to its abundance." The discussion is turgid and unclear.

68 3*Ja The figure of 13 8 million dollars is deceptive. The total project cost could then be presumed to be 15 8 million, but it is now really 181 million (page 9). It might also be appropriate to predict the actual expected cost given the current rate of appropriation.

70 3^c All this mitigation of the borrow areas sounds good, but I am unfamiliar with any other examples where it has taken place. If It is initially unsuccessful, how long will the Corps keep trying to "revegetate" the area?

71-2 35 The vertical drawdown Is of interest, but of more importance is the extent of exposed area during the average recreation season and at other times. A vertical drawdown of 260 feet below the clearing line would presumably expose thousands of acres of reservoir bottom: how many? Ares these the "spectacular views" referred to on page 72?

72 35 There seems to be a conflict between the "spectacular views" and the "unattractive drawdown zone."

76 *J0 This can only be called "hearsay." 77 ^1 If this project were not so far along, this paragraph could only be described as shocking. It is completely inadequate if there is to be any serious consideration of real alter­ natives. Clearly there are more alternatives than just building the nresently authorized reservoir at alternative sites. What about a 9 0 0 , 0 0 0 AP reservoir at the Tulloch site? It would inundate none of the river upstream of the present Melones reservoir, but still could undoubtedly pro­ vide most of the water quality, fish and wildlife, recreation and flood control benefits of the much larger New Melones Project. The main loss would be the irrigation benefits and hydroelectric benefits of the larger reservoir. "Rut since it is likely that the water is not needed for irrigation, this is no real loss. I find it amazing that after much corres­ pondence and many conversations with the Corps -Including Colonel Donovan and General Camm -no mention of the smaller raised Tulloch is made. I know of no investigation of the possibility of a reservoir upstream of Camp Nine. Contrary to the state­ ment made, the only part of the watershed which would not be controlled would be the South Pork of the Stanislaus.

79 *llc The exact cost of inundating the Stanislaus powerhouse at Camp Nine is of interest, since if any water is to be pur­ chased from P G & E for whitewater mitigation, it will dim­ inish the value of this powerhouse. Also, typical misplaced economic priorities are shown again here: powerhouses can stop a reservoir, but a wild river cannot.

80 ^3b The real "need" for the reservoir is revealed in this statement. There is no reason the agricultural lands can not be managed through a flood plain management plan. Some of the world's most productive agricultural areas survive in uncontrolled flood plains, as the KIS later points out. Much of their fertility comas from periodic flooding. In the Central Valley man has replaced this periodic nourishment of the soil with artifical fertili­ zers, and is paying for it through rising levels of nitrates in ground and surface waters.

8l 4*1 1.6 million acre feet in addition to what amount? In what way would releases from New Melones be used to assist in meeting increased flow requirement into the Delta. This section, which presents a viable alternative to the project as presently proposed, should be greatly expanded. A man­ agement plan for letting all the water from the project not used in the local area into the Delta throughout the year should be fully and adequately explored. 82 45 The planned protection" of the riparian habitat is continually referred to, but is nowhere spelled out in any detail. At the moment, it seems most likely that the "ultimate destruction" will occur unimpeded by Corps action. The construction of new homes, referred to here and elsewhere, should be substantiated by reference to areas near other reservoirs. The activity (or lack of it) near Don Pedro, may give some indication of the desirability of such locations.

89 51 The device of using the category of "unreconciled conflicts" to contain problems which won't otherwise go away is unsatis­ factory. One of the purposes of preparing an environmental impact statement is to try to resolve conflicts by finding alternatives which can satisfy as many of the goals of society as possible. Clearly the entire impact statement is written with one goal in mind: the construction of the New Melones Project as presently planned and authorized, with as little / expenditure as possible on such problems as Whitewater ^ boating, caves, riparian habitat, wildlife, fisheries, and so on. Therefore, there has been no real consideration of alternatives, especially those which might cost more.

90 51 It is not true that water from the Stanislaus (from New Melones or any other project) to the amount of exactly 325,000 AP is required either for irrigation or for improving Delta water quality. Nothing in these comments, or in those by any other agency or organization we know of can be taken to imply the above statement. There is no evidence for the statement. It is only another indication that the Corps intends to build exactly this project, and is totally unwilling to consider alternatives. ^

91 51 The actual water rights should be mentioned in this section; as stated earlier, they are allocated to the East Side Division. SIERRA CLUB Mills Tower, San Francisco 94104

March 13, 1972

Colonel James Donovan Sacramento District Army Corps of Engineers Federal and Courthouse Building Capitol Mall Sacramento, California

Re: New Melones Project: Draft Environmental Impact Statement Dear Colonel Donovan:

I am writing to you concerning the New Melones Project Draft Environmental Impact Statement. I refer to my letter to you of July 6, 1971, in which I outlined the Sierra Club position in this matter. In this letter I wish to present the official view of the Sierra Club, as developed by the Water Committee of the Northern California Regional Conservation Committee. I have also incorporated the comments of the Yokut Wilderness Group of the Mother Lode Chapter of the Sierra Club.

In my letter last July I urged that a thorough, factual and ob­ jective examination of the reasonable alternatives for meeting legit­ imate water and flood control needs be made. The present Draft State­ ment does not accomplish this. It is clear from the Statement that the Corps is committed to the project as it is presently designed, and that no real consideration is being given to alternatives, such as no project, an altered project, or a project in another area. We urge you to give much more serious consideration to these alternatives.

Decision 1379 of the State ’Water Resources Control Board, if it stands, will require large amounts of water for water quality in the Sacramento-San Joaquin Rivers Delta. If the East Side Canal is built, more dams will have to be constructed, probably on California's North Coast, to satisfy this demand. Without East Side, New Melones water could be used in partial satisfaction of this requirement, and in response to New Melones authorizing language providing priority uses of water for the Stanislaus River Basin. We feel that the Corps should take a stand on the relative merits of the East Side Division versus the needs of the Delta. Our view is that the East Side Division should not be authorized, and that the water from the Stanislaus should be allowed to flow into the Delta. It should be very clear in the Environmental Impact State­ ment that the prime cause of environmental concern about the New Melones Project is the proposed use of the water in the East Side Division. There is a growing body of evidence which indicates that there is already an overproduction of agricultural crops in California, and that the State Water Project will only aggravate this condition. The East Side Division (as supplied by the New Melones Project) might deal a final blow to California's agri­ cultural economy.

The New Melones Project, if constructed at all, should only be of a size which would accomplish the benefits of flood control, fisheries, and water quality. These benefits could largely be met by a reservoir with a capacity of about half a million acre feet. Or Tulloch reservoir could be replaced with a reservoir with a cap­ acity of about a million acre feet. A reservoir of this size could also provide water for Delta quality. This impact statement does not consider these alternatives.

While some mitigation for the upper river (from Camp Nine to Parrot's Ferry) is discussed, there is no indication that any miti­ gation will actually take place, nor is there any estimate of the cost of such mitigation. Would the Corps purchase water from P.G.&E on the Stanislaus or any other river? How much would additional access roads or other facilities cost on the Stanislaus above Camp Nine? Has the Forest Service been consulted regarding new roads in the National Forest?

Proposals for replacing the white water recreation area of the Stanislaus are incomplete and most unsatisfactory as they now stand. The Sierra Club cannot accept either your environmental impact state­ ment or your statement at subsequent public meetings in this regard. It is apparent that mitigation for the lost white water area will have to be found on another river such as the Tuolumne, and that you will have to seek authorization from Congress for such a program. The Sierra Club must Insist that a firm commitment from the Corps to approach Congress for authorization for such a program be included in the impact statement before it can be considered acceptable.

The discussion of the limestone caves in the area is less than adequate: what effect will the reservoir have on those caves which will be periodically Inundated? Is ther yet any guarantee of preser­ vation for the Natural Bridges in the area?

Programs outlined by you for mitigation of environmental losses along the lower Stanislaus River and for preserving limestone caves around the reservoir, particularly at your meeting March 2 in Modesto, reduce, but do not remove, our concerns in these areas. Your statement that sufficient authorization has been provided for these programs from the Chief of Engineers is encouraging. The project presently has a B/C ratio of only,1.2 to 1 for a 50 year period, and the Interest rate Is unrealistically low. How much money is available for mitigation? Is it true that only two million dollars can be spent on any one phase of mitigation before the approval of the Office of the Corps of Engineers is required?

The question of guarantees of various types of mitigations is a troublesome one, especially when it is not clear which type of mitigation is the most desirable, but I think you can under­ stand our reservations about anything other than a firm guarantee of mitigation. The best intentions of many agencies have been destroyed by the Office of Management and Budget or by Congress.

We urge that the project be re-evaluated in light of the new proposed Water Resources Council Guidelines regarding the con­ struction of water projects. These guidelines are evidently the way society now wishes to look at water projects, and the New Melones Project is not so far along that it cannot be re­ considered.

New Melones will be operated by the United States Bureau of Reclamation as part of the Central Valley Project when it is com­ pleted. The Corps has demonstrated no ability to bind the Bureau to Corps commitments once the project has been completed with respect to alternative uses of New Melones water. The Bureau should at least co-author the Environmental Impact Statement.

Mr. H.E. Horton, Assistant Regional Director for the Bureau of Reclamation, speaking on behalf of Regional Director Pafford, at the March 2 meeting in Modesto, offered a most disappointing explanation of Bureau intentions toward operation of the New Melones Project. Mr. Horton said the Bureau intends to honor all commitments of the United States toward use of New Melones water, but specifically avoided terming them commitments of the Army Engineers.

He furthermore said, "As operation of the New Melones Project is some 6 years away, it is premature now to define precisely the exact operating details and their specific impact on the environment. These will be firmed up within the next few years. Prior to init­ iation of operation, a supplementary environmental statement will be prepared by the Bureau."

Prom the beginning, the Sierra Club has urged the Corps to provide a thorough analysis of the New Melones Project, and of the alternative uses of New Melones water. We have specifically asked for an analysis of the East Side Project and its environmental impact. Mr. Horton suggests such an Impact study will not be under­ taken until the project is nearly completed, a position which is totally unacceptable to the Sierra Club. The comments of the Environmental Defense Fund are generally in accord with ours. We urge you carefully to consider the points raised by Mr. Meral, who is also the Chairman of the Sierra Club River Conservation Committee.

We reject the use of "unreconciled conflicts" in an Environ­ mental Impact Statement, although we realize that such conflicts may actually exist. We believe that they should be resolved before the project goes forward. Therefore, in accord with the policy of the Northern California Regional Conservation Committee, I request that all work qn the New Melones Project cease until the following conditions have been met: 1) That alternatives to the project b e ’ given an honest and careful evaluation, and the one which is best Justified on both economic and environmental grounds is chosen; 2) The Final Environmental Impact Statement is on file with the Council on Environmental Quality for at least 30 days; and 3) The "unreconciled conflicts" mentioned in the Impact Statement are re­ solved by the Corps, the Bureau of Reclamation, the State Water Resouces Control Board, and other responsible government agencies. This should include the Congress if necessary.

Thank you for the opportunity to comment on the Draft Impact Statement. I look forward to your reply.

Sincerely,

Michael McCloskey Executive Director Sierra Club Enclosure: Yokut Resolution cc: Jake Miller Jerry Meral Lowell Smith Norma Lowry Beatrice Laws Roger Gohring Harold Basey Resolution of Yokut Wilderness Group

Mother Lode Chapter, Sierra Club

Adopted by Management Committee, February 3, 1972

The Yokut Wilderness Group Management Committee recommends that the Sierra Club prepare to enjoin further construction of New Melones Dam on the Stanislaus River until the following conditions have been met:

1) Studies and recommendations respecting management of the riparian habitat, flows, salmon gravel protection, public access to be provided.by the Corps of Engineers, a master plan for levees and the stablization of Woodward Reservoir with New Melones water be completed and authorized.

2) Studies and recommendations for mitigating the loss of white water above New Melones Dam be completed and authorized,

3 ) Studies and recommendations for protecting caves and historical sites such as gold mines and Indian villages to be completed and authorized.

4) A thorough analysis of the environmental impact of the possible uses of so-called new water of New Melones water, including its use after conveyance in the proposed East Side Canal, be completed.

The Yokut Wilderness Group Management Committee expressly withholds its authorization for tne above lawsuit pending analysis of the final environmental impact report. YOKUT WILDERNESS GROUP SIERRA CLUB

Feb. 18, 1972 2150 Park Ridge Dr. Modesto, Calif. 95350 /

Colonel James Donovan District Engineer Corps of Engineers 650 Capitol Mall Sacramento, Calif. 9581^

Dear Colonel Donovan:

Thank you for the new opportunity to comment on your environmental Impact report regarding New Melones Dam on the Stanislaus River. Our last comments on the working paper were sent to you In July.

In general, the Yokut Wilderness Group feels the draft Impact report does a creditable Job of Identifying adverse environmental affects of the proposed dam project. Certainly this will be true after your staff has reviewed and Incorporated the new objections ' trom fclia Environmental Dereuse Fund, in nlilult no uuuuuci rurllier analysis probably*; Is needed of the tapact from alternative uses of New Melones water, particularly If the water Is to be exported from the Stanislaus River basin In the proposed East Side Canal.

The draft report falls short In Identifying and recommending specific ways to mitigate for the environmental losses which are Identified. No programs are recommended for replacing the lost white water recreation area, for saving the caves and natural bridges, for protecting and enhancing the lower Stanislaus River.

INVOLVING SIERRA CLUB MEMBERS IN STANISLAUS AND TUOLUMNE COUNTIES. CALIFORNIA YOKUT WILDERNESS GROUP SIERRA CLUB

The YAkut Wilderness Croup of the Sierra Club»s Mother Lode Chapter, after studying the draft report, adopted the following resolution! The Yokut Wilderness Group management Committee recommends that the Sierra Club prepare to enjoin further construction of New Melones Dam on the Stanislaus River until the following conditions have been met: 1) Studies and recommendations respecting management of the riparian habitat, flows, sAimon gravel protection, public access to be provided by the Corps of Engineers, a master plan for levees and the stabilization of Woodward Reservoir with New Melones water be completed and authorized. 2) Studies and recommendations for litigating the loss of white water above New Melones Dam be completed and authorized. 3. Studies and recommendations for protecting caves and historical sites such as gold mines and Indian villages vu ouuipiukcu tvriu Mubituix&eu. k, A thorough anaLysis of the environmental Impact of the possible uses of the bolcalled new water from New Melones, Including Its use after conveyance In the proposed East Side Canal, be completed. TherTokut Wilderness Group Management Committee expressly wltholds Its authorization for the above lawsuit pending analysis of the final environmental Impact report.

We hope the environmental goals outlined by the resolution can be met, and satisfactorily authorized before the main dam feontract Is awarded. Sincerely yours, ,

Roger E . Gohrlng f INVOLVING SIERRA CLUB MEMBERS IN STANISLAUS AND TUOLUMNE COUNTIES. CALIFORNIA STOCKTON AUDUBON SOCIETY

P.0. Box 7211 Stockton, Ca, 95207 Fob. 24, 1972

Col. James Donovan Distriot Engineer U.S. Corps of Engineers Federal Building Saoramento, Ca • 95814

Dear Col. Donovan:

Mr. Paul Howard the Western Regional Representative for the

National Audubon Society asked our group to read the lmpaot

Statement for the New Clones and to make comments. He also suggested that we submit a copy of our comments to your offloe.

Yours truly.

JoAnne Lamm, President Stockton Audubon Society Comments on Impact Statement on New Melones Dam

The project, in efeot, suggests a trade-off of 10,000 aores of riparian land and 16 miles of river for the benefits gained in irrigation, flood control, recreation, wildlife enhancement and water storage.

A. W ildlife Enhancement The report is hard put to justify the destruction of 10,000 acres of riparian land as being consistent with wildlife enhancement The 2000 acres offered as mitigation do not compensate, they exist already and are not being created by the dam. It is claimed that fishing will be enhanced. According to a report by the Fish and Jams Dept, in Outdoor C alif. Vol. 32:6 Page 10, there has been a serious deoline in fishing in the Trinity ^iver since Trinity and Lewiston Dams were b u ilt. Efforts to restore fishing have not been successful on the Trinity..why would they succeed on the Stanislaus. It is claimed fishing will improve if mining of gravel and water diversions do not ooour below the;dam. There is no oonorete plan for preventing mlnlffg of gravel or water diversions.

B. Reoreation The following reservoirireoreation areas are in the vicinity of Hew Melones: New Don Pedro, Lake Mo Lure, New Hogan, Comanohee, Pardee, Woodward, Farmington and Tullooh. The reservoir at New Melones will offer nothing that these do not already iftffer and will destroy the unique reoreation that the Stanislaus does now offer-—white water boating. C. Irrigation For what crops? Crops already supported by government subsidy! Where in southern San Joaquin Valley? The Frisnt- Kern Canal serves much of this area..why two oansls? #h«t orops in the Farming ton-Cals versa area? I t appears that only marginal land could be brought into production in this area? Chat is the land ownership In the area to be irrigated? As we understand the law, a married oouple oan only irrig ate 320 acres with Bureau of Reclamation water..the rest of the land must be sold. Thus if the land holdings are in the of a few owners (as is surely the oase in Kern, iiadera, and Tulare counties) irrigation water will lead to land being sold off for development, not agriculture as olaimed.

D. Flood Control What is the nature of the $50 million flood? What damage and to what? It is stated that suburban Oakdale, Klverbank, and Rlpon oould be protected by levees (oheaper and less damaging to the environment.) What .>ams now exist on the Stanislaus and other rivers that did not exist in 1906, 1938, and 1952 whioh are olted as high flood years. The report states that flood control is needed to provide protection for agricultural and other development .of the flood plain down river from the dam. Then it states that such development is undesirable and good local planning and zoning would be needed to keep i t under control. The Engineers won't be around to see that this good looal planning and zoning takes plaoe. What will happen to the natural prooeaa of soil formation by silt on the . lood plain when periodic floods are stopped? The reservoir will trap 10,000 aore feet of sediment in 100 years. Fertilizer is suggested as a substitute but fertilizer is rxpensive and often leads to water pollution through run-off of phosphates and nitrates.

E. Uses for the Stored Water No legitimate need for the stored wt

F. Cost-Benefit The oost-benefit ratio is low and is based on an unrealistic interest rate of 3 1 /8 $ , on questionable recreational use, and on delivery of water to oontraotors who may not want or need that water. Have monies been allocated to the Bureau of Heclamation to develop the recreational facilities from which the benefits will supposedly arrive? Heoreation is not the true function of the Corps of Engineers. The 0 0 3 t is immediate and the benefits, if any, are in the future. Have the benefits been oaloulated to take into aooount dollar shrinkage due to Inflation? Have the oosts of mooing part of Hwy 49 and other oounty roads and the oosts of the destruction of the Old Oam and powerhouse been added into the oost?

G. Soenlo Enhancement

'V There would be a 40 foot drawdown between Memorial and Labor Day. There would be a visible exposed so il gap of less than 50 vertioal feet from clearing line to the water o surfaoe. The term vertioal feet is meaningless. Average horizontal feet would be meaningful and show the extent of the denuded area. A treeless reservoir with denuded banks hardly seems to "inorease the soenlo value of the area". Hughson, California 2b Fab 1972

Colonel Janes Donovan Corps of Engineers 650 Capitol Mall Sacramento, California 9581^

Derr Colonel Donovan1

The general reaotion of the National Speleological Society Task: Force toward the draft Environmental Impact Statement if favorable* I would like to caaplimentyou and your staff for the efforts toward preservation of these unique resources*

A few further contributions and suggestions will be briefly given. The Indian Petrogyphs are not in a cave but on the face of the cliff about 100 feet above the river and approximately 3/^ mile upstream from the Parrottts Ferry Bridge on the north side* They will be inundated but could be viewed during periods of low water*

It might be mentioned that spelunking as a recreational resource is unique in that it is a year round sport* Extremes of temperature are nullified since the temperature in a cave varies less than two degrees and is for all practical purposes the mean outdoor temperature* Being above the fog zone and below the snowline, caves in the area average about 56 degrees* Day­ light is also not required for the sport* Caves present conditions of nearly absolute darkness and silence*

Some abandoned gold mining equipment is located on the south side of the South Fork below Pine Log* An unusual rotary stamp mill is included and probably will be pilfered when the reservoir rises* It should be removed to a museum*

Some facts about McLeans (Save, the principle major cave to be inundated, should be considered* The entrance elevation at 990 feet above sea level is about 30 feet below average recreation pool, but the most beautiful upper levels are about 30 feet above the entrance level* This is not onls rare, since most caves in the area are much deeper than the entrance, but'there are possibilities of another entrance being found higher on the hill that could be used* Ordinarily, descent 25 feet below the entrance is necessary before climbing to the upper levels*

Since the roof of the entrance room of McLean's Cave seams to be composed of a red clay composite material cemeted by calcite, it may represent a formerly open sink hole* If so, it could contain^ a fossil assemblage dating either to the pleistocene or lato pliocene geological eras* The resolutioning that will occur could cause this to break off in chunks and fall to the floor of the cave where archeological and paleontological research could be per­ formed* This should be another reason for proper gating techniques of the inundated cave (I*E*| Fine meshed screen) Caves below gross pool will undergo extensive solutioning and re- solutionlng since the fresh water will be greatly undersaturated with Calcium and Magnesium ions* In addition, sulfate minerals in the inundated mines and mine tailings will probably generate subetanlal qualities (at least as far as the basic limestone is concerned) of anritfat sulfuric acid. If this gets to be a significant problem, it could lead to the collapse of some poolside caves and be a possible hazard to boating, swimming, etc*

This accelerated solutioning could be used as an interesting study in speleogenesis* The resolutionlng or reverse process to sqm speleothen growth, although regretted, could in this instance also present an unusual speleostud$ opportunity* These opportunities, also, are reasons for proper and controlled entry into the caves through gating techniques in a geologic! preserve.

The reproduction of skeetens,a principle in the diet of bats, will be increased by the reservoir* This should lead to potentially increased bat populations* Both from the point of view of preserving the bats (which have been decreasing in population in the United States), and for safeties sake in rabies control; the recreational opportunities should be controlled and interpreted by a geological preserve*

The limestone weathers to form a chemically neutral soil, therefore, a large diversification of plants can be found in the area that are unique to the area* The National Speleological Society defers study of these to other interest groups*

Amorist the wildlife that will migrate as the water rises is the rattle­ snake* They exist in great numbers in dens near the river and may effect adjacent landowners adversely by their unsettled presence* This fear was expressed to me recently by a Calaveras County cattleman. If the water rises rapidly during very cold weather, (Hibernating time), the snakes would probably drown; but if the rise is later during the warmer weather of the snow melt period, they could present seme hazards*

There is little evidence that the larger living organisms within the caves to be inundated will migrate. The ecology of the caves is very confining as well as fragile* I believe that interested persons may be available who could collect specimens prior to inundation^ for the purpose of relocating them to similiar caves above gross pool* If a geological preserve is created soon and a committee of qualified speleologists is appointed in an advisory capacity, as recommended, they could coordinate many such activities and studies with a minimum of"fanfaae'and expense to the governing agencies*

Thank you for this chance to comment* I understand that we will have a chance to make a formal responce to the final edition. The final printing of our Report of Study, presently being revised and upgraded, will probably be available by that time and oould be forwarded as an addendum to the EPA* I have attempted to keep your staff aware of any findings that I have made*

Sincerely,

Ralph E* Squire, Chairman New Melones Task Force National Speleological Society THE WILDLIFE SOCIETY FOUNDED 1937

CALIFORNIA - NEVADA SECTION

February 28, 1972

James C. Donovan Colonel, CE District Engineer 650 Capitol Mall Sacramento, California 95814

Dear Colonel Donovan:

Thank you for your letter of January 10, 1972 with two copies of the draft Environmental Impact Statement for the New Melones Project on the Stanislaus River.

The Sacramento Chapter of the Wildlife Society is most happy to be allowed to review and comment on the draft EIS, however, working with voluntary labor makes such a review a slow process. Because of our inability to make a complete review and investigation of the Project, our comments will be directed to the data furnished by the draft EIS.

The draft EIS supplies the number of acres of wildlife habitat that will be inundated but there are no numbers or estimated numbers of wildlife popula­ tions involved in this 10,700 acres. It is difficult to assess the environmental impact of this project without knowing such data.

Since the 4,719 acres of mitigation land is located in the same general area of the project, it is assumed that the mitigation land is presently carrying about the same density of wildlife as the land to be inundated. If this is so, how can 4,719 acres of land which already has a wildlife population on it, mitigate for the loss of 10,700 acres of habitat? The report leads one to believe that "wildlife cultural practices" used on the mitigation lands will enable this 4,719 acres to not only sustain the wildlife population it already has, but also to support the additional number of wildlife displaced from the 10,700 acres inundated by the reservoir. This is highly unlikely and very misleading to those readers who are not knowledgeable with wildlife management.

Although "wildlife cultural practices" such as removal of or other manipula­ tion of the old stands of chaparrel will enhance most wildlife habitat, the EIS did not indicate how this on-going management activity was tojlfinanced. Without a program and plan for financing these on-going wildlife management activities, such activities will lag behind and the wildlife displaced from the 10,700 acres will surely disappear. To bffset such a direct loss of wildlife, it is the recommendation of the ; Sacramento Chapter of the Wildlife Society that the riparian land for ! several miles below the damsite be acquired for wildlife purposes. Publicly owned riparian wildlife habitat is at a premium throughout the foothills and in the San Joaquin Valley. This uniquely located land would be a tremendous asset to fish and wildlife as well as providing access and space for other recreational purposes.

We have purposely kept our comments short and directed to the subject of wildlife. Much could be said about the fishery and outdoor recreation, but we leave those topics to other disciplines for comment. We appreciate the opportunity to comment on your draft EIS and urge you to consider the acquisition of downstream riparian lands to assist in mitigating the loss of wildlife from the 10,700 acres of habitat to be inundated.

Sincerely,

RICHARD LAURSEN, President Sacramento Chapter The Wildlife Society TU.' tOu/Ofu /(Uocla£IoM/

A non-profit educational H$oci«tion. Telephones — Area 415/465-9355 1016 Jackson Street (Outside of California) Oakland, Calif. 94607 BQSftHiMttxxttikirMt March 1, 1972 Colonel James C. Donovan Corps of Engineers 650 Capitol Mall Sacramento, Ca. 95814

Dear Colonel Donovan:

I wish to thank you for extending the time for receiving my comments on the Draft Environmental Impact Statement. This has enabled me to benefit from your meeting on February 28 with various white-water groups relative to the New Melones Project. In making my response, I will refer to both the Draft EIS and to the recent meeting in forming my conclusions.

First, I wish to express my appreciation, and that of fellow conservationists closely concerned with the Stanislaus, for the forthright way you have discussed the problems of the New Melones Project with the public and with the white-water groups in particular. Regarding the latter, it took no small amount of courage to face the most vocal critics of the dam project. While differences were obvious, you expressed a growing concern for the environmental and social consequences of the New Melones Dam, and this won personal respect for you and a more trusting attitude toward the Corps of Engineers in general. I hope this trend con­ tinues and that the Corps will soon adopt comprehensive responsibility for the ecological welfare of the total life environment.

In my response of November 10 to the preliminary EIS working paper, I made a close comparison of planned benefits for the New Melones Project to existing wild river values on the Stanislaus River. There is statistical evidence to show that reservoir recreation is leveling off while wild river recreation increases dramatically each year. I admit that your user day figures are much greater than those provided by present or future users of the Stanislaus. However, the situation is wholly unique in that the wild Stanislaus between Camp 9 and the Parrot's Ferry Bridge is irreplaceable.

There are many existing reservoirs that can easily accommodate a resurgence in deadwater recreation in the future— and more w ill be built irrespective of the New Melones Project. But there is only one suitable river left for year-round white- water sport, and this is the Stanislaus. The popularity of wild river recreation is proven, and it can continue to grow only on this river.

We are talking about social values that thrive in a near ideal environment. In my earlier response, I cited the trend toward wilderness experience as demonstrated in nearly all facets of outdoor recreation. I implored the Corps to acknowledge this trend. Yesterday's mold does not fit today's form and must be reshaped if man is to become more humane and less enslaved. I cited particular aspects of the wild Stanislaus. The presentation of rapids of average difficulty that bring boating adventure to skilled oarsman and river tourist alike. The natural access the river provides to over 20 ideal sites along the way for people who enjoy shore camping. The access it gives hikers who like to explore side-canyons or limestone caves. River-related pursuits available to fishermen, gold-panners, back-packers, picnicers, and general sight-seers. The aura of historic Gold Rush days, the vista of the river canyon, and the aesthetic delights of wild flowing water that appeal to all people who come to know the Stanislaus. They are easily available to major population centers in the state. They are the varieties of wilderness experience. The blend together to create an absolute social value without substitute in California.

The Corps of Engineers is increasingly aware of the importance of present re­ creation of the Stanislaus. The river is unrivaled by any other existing stream in the state, and the Corps has expressed a sincere desire to mitigate the loss of this unique resource. However, suggested alternatives are clearly unacceptable. The 7 mile stretch of river above Camp 9 is universally deemed impractical for any relevant form of white-water boating. The gradient of the river at this point is too steep to allow safe navigation (as a rule of thumb, professional outfitters classify any river that drops over 45' per mile as too dangerous! Even if it ' were practical for running, the rapid fall in elevation would cause the river to flow so swiftly that the 7 mile voyage would be completed in less than 2 hours under average water conditions. An especially heavy spring run-off would, indeed, turn this part of the river into a hazardous torrent unsafe for any kind of boating. The amount of water purchased by the Corps for boating purposes (250 cfs) is grossly insufficient. A flow of at least 850 cfs is considered minimal for safe and enjoyable sport by raft or kayak. To look to other rivers as. alternatives to the Stanislaus is fruitless. There are none that even approximate the values of the Stanislaus in meeting a broad range of public interest in wild river recreation. The Tuolumne River between the Lumsden Bridge and Ward's Ferry is considered too difficult for the average river runner. And people who wish to run the river with a professional rafting company are required to have prior river experience (normally obtained on the Stanislaus). Other rivers like the Eel and North Fork of the American are suitable only for the most highly skilled boatman who represents just l7o of the boating public. These rivers, like the Tuolumne, are limited by short and unpredictable boating seasons. The Stanislaus offers year-round recreation for the greatest number of people.

The effort to mitigate the destruction of wild river values on the Stanislaus River is commendable. But alternative waterways or white-water management plans are not worthy of recommendation. Too many rivers have already been dammed, and those that remain are not nearly as well suited as the Stanislaus for popular enjoy­ ment. Reservoirs abound throughout the state, and justice demands that this river remain for the people who increasingly depend on it alone for wilderness sport and pleasure. M arch 1, 1972

My recommendations, then, are to abandon the proposed New Melones Dam in the absence of any viable mitigation for the river oriented public. The projected benefits of reservoir recreation for the dam project, however well supported by statistical fact or fancy, are unrealistic and destructive of more relevant social values. They should be struck from the current benefit-cost ratio used to justify dam construction. Finally, the Army Corps of Engineers must prove full consideration of alternative dam sites and other methods for providing basic flood control. To paraphrase Ron Hayes of Los Angeles, the real task is not to seek alternatives for the wild river enthusiast. Rather, we must seek a workable alternative for the New Melones Dam.

I wish to thank you again for requesting my comments on the Draft Environ­ mental Impact Statement. I have given my personal observations, yet I have also tried to communicate the convictions of all persons who support present and future wild river values for the Stanislaus River. Please let me know if I can provide further assistance. I look forward to your response.

S incerely,

David A. Kay Public Affairs & Conservation AMERICAN RIVER TOURING ASSOCIATION

PACIFIC RIVER OUTFITTERS ASSOCIATION The proposal to build the New Melones Dam first was made some 25 years ago under the Flood Control Act* -f. If flood protection was the main purpose, we have lived without^these last 25 years - which indicates there is no real urgency to this purpose* XJHfr What have been the actual costs in flood damage to the lands directly affected? What are estimated costs from this supposed threat? What percentage does this water system contribute to the overall Valley flood threat? Is it really appreciable?

In the listed alternatives* channel and levee improvements are dismissed as "expensive." What does this mean in actual costs? How do they comnare with the $1811,000,000 estimated coats for the dam - and the loss of the white-water recreational area?

On Page 8^ acknowledgment is made that the annual run-off is bene­ ficial to the soil of the valley, but it is stated that chemical fertilizers can take the place of this. There are grave questions as to whether chemical fertilizers can ever replace this natural process, and 'as to their effect on the produce as well as on the soil* Have these possible costs been taken into consideration in establishing a cost-benefit ratio? The economic direction which will be given the area with the build­ ing of the dam has been touched upon only superficially. It has been pointed out that some of the crops which are most suitable to the area already are on the surplus list and are being subsidized by the government* As far as real estate development is concerned, the denser housing which may result will change the character of the surrounding area considerably, with attendant problems of waste disposal, air pollution, etc* The long-term economic forecast should include these factors as well as short-term increases in property values*

The entire question of evaluation of recreational activities is presently under study by various government agencies and private institutions working under government contract, e.g., evaluation of rivers for possible inclusion in Wild and Scenic River System under Department of Interior, Office of Water Resources* The present trend is to value usage in ter^s of quality rather than quantity alone* A wilderness experience such as a river tour on a white-water river, for example, would rate consid­ erably higher than a corresponding number of days s -ent on a crowded* man-produced lake,water-skiing behind a motor boat. Although both types of recreation hold a different subjective value for the indi­ vidual involved, it is felt that an overall estimate of value for the average citizen can be placed on these activities* Because of the rareness of the experience and its contrast to the pressures and unaesthetic features of modern urban life, the wilderness xiver tour ranks high in recreational, refreshment value, as compared to the activities which would be available on a man-made lake* We believe that no further evaluation of cost-benefits is possible without recourse to the most recent studies on this subject, and we ask for inclusion of these factors in any final environment report* Historical and archaeological values also should be re-examined* How does the exo*rience of standing beneath the arch of an old and beautiful Indian cave*, sculptured by the river, and running one's hands over the indentation in the bedrock worn by__the hands of Indian women grinding acorns long ago, compare-to looking at a rock under glass in a well-lighted visitor center?

What is the educational value to youth of seeing with their own eyes the spots where Mark Twain rambled, or XXe finding the rem­ nants of an old mining enterprise along the river? Does it not seem ironic to * inundate these histor'- spots, and then name XXo a visitor center# after Mark Twain? (He would appreciate the irony, and no doubt have some withering comment, but unfortunately we are denied the pleasure of adding his name to the list of those who hope to save the Stanislaus*;

Perhaps we can gain others, however* The only true public meeting on this subject was held 12 years ago, in I960 - except for some small local public meetings held in the area, mainly with persons interested in real estate development* In the meantime there has been a fundamental change in public thinking on conserva­ tion, ecology,' and wilderness values. And in the meantime, the Stanislaus has gained the stature of a national resourcei a lovely stretch of white-water which is one of the most popular river runs in America today* No decision should be made on its future without theoough public understanding of the issues involved, and without greater expression of the public's views* RONALD REAOAN OOVfRNOR OF CALIFORNIA

THE RESOURCES AGENCY OF CALIFORNIA SACRAMENTO, CALIFORNIA

May 23, 1972

Colonel James C. Donovan District Engineer Sacramento District U. S. Army Corps of Engineers 650 Capitol Mall Sacramento, California 95814

Dear Colonel Donovan:

This is in response to your letter dated January 7, 1972, to the State Clearinghouse, Office of Intergovernmental Management, requesting comments on the "Draft Environmental Impact state­ ment, New Melones Lake, Stanislaus River, California".

The review accomplished by the state fulfills the requirements under Part II of the U. S. Office of Management and Budget Circular A-95 and the National Environmental Policy Act of 1969.

The State's comments on the draft environmental impact statement were coordinated with the Reclamation Board, State Water Resources Control Board, the State Lands Division, and the State Departments of Agriculture, Conservation, Fish and Game, Navigation and Ocean Development, Public Works (Division of Highways), Public Health, Parks and Recreation, and Water Resources. The state's comments are as follows:

Acquisition of Riqht-of-Wav for Flowage and Channel Maintenance and of Riparian Lands for Wildlife Preservation and Fisheries Enhancement

Section 10, Downstream Channel, on page 9 indicates that the reach to be maintained by the Secretary of the Army extends from Goodwin Dam to the San Joaquin River. In view of the State Reclamation Board's flood control project responsibili­ ties and the nonfederal local interest requirements, we are concerned that this statement may not clearly indicate that the reach to be maintained by the Secretary of the Army extends from Goodwin Dam to the mouth of the Stanislaus River. The use of "San Joaquin River" as the lower terminus could be interpreted to mean the backwater of the san Joaquin on the Stanislaus. We suggest that language be modified to eliminate any doubt as to the downstream end of the reach to be maintained The Corps' channel maintenance requirement should apply to the entire length of the channel from Goodwin Dam to the mouth of the Stanislaus River.

The statement indicates that private levees will be included in the floodway to contain flood flows of 8,000 cfs and will be maintained by nonfederal local interests. By including such levees, the levees in effect become project levees and rights-of-way therefore would be acquired by the Reclamation Board.

We believe that some of the private levees may not be adequate to carry the design flow. It may be necessary for the Corps to strengthen some reaches of the private levees to make sure that they will carry the 8,000 cfs.

The statement indicates that a study was initiated late in 1970 to determine the need for possible acquisition of riparian lands downstream from the reservoir for fish and wildlife mitigation and enhancement, public access, recreation, and related purposes, we suggest that the need for rights-of- way for channel maintenance should also be determined.

The Bureau of Sport Fisheries and Wildlife recommended in its January 25, 1971, report on the project that the Corps acquire in fee title or easement all lands inside the levees below the 8,000 cfs flow line between New Melones Dam and the confluence of the San Joaquin River. The Department of Fish and Game concurred in this recommendation. These lands would be an integral part of the wildlife mitigation program to offset project-associated losses of habitat caused by reservoir inundation (10,700 acres) and accelerated land development along the river. The State Lands Commission notes that any such acquisition program should take into account the existing public ownership and rights in land in the bed of the river. Acquisition of these lands is also important to the preservation and enhancement of Stanislaus River anadromous fisheries. The Department of Fish and Game acknowledged in 1964 that, with anticipated post-project streamflows and protection of existing spawning gravels, an increase in fish runs of 8,000 king salmon and 1,500 steelhead would occur. The annual monetary value of this increase is $424,000 — an enhancement credit to the project.

The impact statement acknowledges the need for acquiring riparian lands for these purposes. Since the final decision, however, "to acquire" or "not to acquire" has been delayed pending completion of the land acquisition study that was initiated late in 1970, there is no assurance that the wildlife losses will be adequately mitigated or that the $424,000 annual fisheries enhancement benefits will occur.

Routing and Use of 325,000 Acre-Feet Annual New Water

As it is pointed out in the statement, one of the primary unreconciled conflicts of the project concerns the use of the new water yield of 325,000 acre-feet per year. After construc­ tion, the project will be operated by the U. S. Bureau of Reclamation as part of its Central Valley Project. Studies conducted by the Bureau indicate that several potential service areas exist. The statement indicates that among these are:

(a) the Stanislaus River Basin (b) north of the Stanislaus River in the Farmington- Calaveras area (c) south of the Stanislaus River (d) the southern San Joaquin Valley could also possibly be served by Stanislaus River water flowing to the Delta and being diverted from the Delta and trans­ ported via the Delta-Mendota Canal or the California Aqueduct and a Cross Valley Canal (e) the southern San Joaquin Valley area via the East Side Canal (f) an additional possible use of the water mentioned by the Corps would be for water quality purposes in the Delta pursuant to State Water Resources Board Decision No. 1379, July 1971 The final destination of the water, the purposes for which it would be used, and the manner that it would be conveyed are extremely important factors to the overall impact of the New Melones Project on fish and wildlife.

There are two major problems associated with "water routing":

The first problem is anadromous fisheries enhancement as related to strearaflow in the Stanislaus River. The previously mentioned $424,000 annual enhancement benefits to the project is contingent on several factors, including high post-project streamflow. The statement indicates that if the new water yield is transported via the Stanislaus River to the Delta, then average monthly flows in the river would range from 500 cfs to 1,000 cfs January through August, and from 200 cfs to 400 cfs September through December. With these flows, we believe that the predicted salmon and steelhead enhancement would occur.

If the water is diverted, however, at Knight's Ferry to the East side Canal or similar conveyance system, then the Stanislaus River flows below Knight's Ferry would range from 130 cfs to 400 cfs January through August, and 130 cfs to 200 cfs September through December. Despite our 1964 finding, we now believe that anadromous fisheries enhancement would not occur at these flows — hence the $424,000 annual fishery benefit would not accrue to the project.

The second problem is the indirect effect on wildlife in potential service areas. The Corps predicts that the new water yield could irrigate 100,000 acres of presently uncultivated, wild lands. Additional wildlife habitat losses could occur as a result of land use change. The State recognizes that use of this water may not result in a land use change; project water may replace waters presently pumped from the groundwater basin. The magni­ tude of losses would vary, depending on the specific service area, crops produced, acreage, and conveyance facilities involved. These effects must be evaluated as soon as the specific service areas are delineated. Additional wildlife mitigation measures may be necessary, contingent on the findings of that evaluation. We understand the Bureau of Reclamation will prepare an environmental impact statement on the 325,000 acre-feet of annual new water yield prior to completion of the dam in about six years. Prior to completion of the Bureau's environmental impact statement, provision should be made for future acquisition of additional lands if needed.

Fire Prevention

The Project reservoir is located in an area which is protected from fire by the California Division of Forestry. Experience has shown that the risk of fire starting from water project construction activity is multiplied many times over normal conditions. When recreation is included as a project purpose, the additional people that will use the area also increase fire occurrence and risk to human life. Access from existing fire suppression stations to the point of origin of fires can be adversely affected temporarily or permanently. Clearing the reservoir site is a very fire-hazardous activity.

In order to realize the anticipated benefits of the project, it is essential that fire losses in the watershed lands immediately adjacent to the project be held to a minimum. In an attempt to accomplish this, the Division of Forestry on October 17, 1967, met with representatives of the Corps of Engineers and recommended additional fire protection needed during the construction period. The Corps agreed with the Division of Forestry on fire protection improvements to be installed on the land, including access roads, heliports, firebreaks, etc., provided the features were authorized and the funds were made available.

Page 69 of the statement states "Construction activity would increase the risk of fire with subsequent increases in a sedi­ ment load that would be introduced into the river during runoff The agreed upon fire protection measures will decrease erosion and protect esthetic values and will insure the realization of anticipated benefits (including recreational use) of the structural works of improvement to be installed with public funds. Further, the measures will reduce air pollution from smoke and maintain water quality by reducing the amount of pollutants (soil, ash, debris) from reaching the water and will reduce maintenance costs. We suggest the statement be expanded to specifically indicate the agreed upon fire protection meas­ ures.

Recreation Aspects

We request that a more definite presentation be included in the statement concerning the proposed recreation facilities planned for the reservoir area, including a proposed time schedule for construction. The statement indicates that studies are in progress to prepare a master plan for public recreation use. we would like the opportunity to review the plan.

Water Quality Considerations

In the fall of years when flow in the San Joaquin River at Stockton is low enough to cause a dissolved oxygen "block" detrimental to anadromous fish, the Bureau of Reclamation and the California Department of Water Resources under agreement with the Department of Fish and Game have taken action to eliminate the problem. In the interest of completeness, we request this be recognized in topic 17, page 20.

We believe the following concerns of the Water Resources Control Board relating to water quality should be discussed in the statement.

1. The project's long-term capacity to maintain salinity at 500 mg/1 at the Vernalis station on the San Joaquin River. We are concerned that the increase in irrigation use, the increase in salinity within the reservoir due to evaporation and out-of-basin exportation, should the 325,000 acre-feet of project yield be diverted to Knight's Ferry, might combine to negate the beneficial effects of the water committed for water quality control.

2. The effect on the dissolved oxygen regimen of the receiving waters of the lower San Joaquin River and the southern Delta which might be caused by releases of algal-containing waters from the reservoir at critical times of year. 3. The effects of the virtual complete elimination of flushing flows, we are concerned the long-term result of this might be increased eutrophication of receiving waters.

4. The effects of the discharge of dissolved iron and manganese which may be contained in the anaerobic waters men­ tioned on page 47 of the statement.

5. The effects of a single release point from the dam on temperature and other water quality factors. We feel a multi­ level outlet has many potential benefits.

6. The additional salinity contributed from expanded agricultural activities should be included in topic 39 on page 76.

Conclusion

We appreciate the Corps' efforts to create an environmentally acceptable project and will continue to work closely with the staff of the Corps to accomplish this mutual goal, we request that the foregoing comments and suggestions be incorporated and be given full cognizance in the final statement, in addition we request that the revised statement give assurance that riparian land along the Stanislaus River be acquired in accordance with the recommendation of the U. s. Bureau of Sport Fisheries and wildlife and the State Department of Fish and Game. We request that we be given ample time in which to review the final statement.

The State will expect to comment again on the final environ­ mental statement and reserves the right at that time to also voice their opinion on the overall aspects of the project particularly as to (1) the use of the new water yield of 325,000 acre feet per year, (2) a detailed benefit/cost com­ parison between the 1,100,000 acre-feet reservoir recommended in 1959 and the current recommendation of 2,400,000 acre-feet reservoir and (3) the relationship between 1 and 2. Thank you for the opportunity to comment on the statement.

Sincerely yours,

N. B. Livermore, CTr. cc: Mr. James A. R. Johnson Executive Officer Office of Intergovernmental Management State Clearinghouse 1400 - 10th Street Sacramento, California 95814 Attention: Mr. Mark Briggs (SCH NO. 72011720) MICIIAEL W. PALMER, ESQ. THOMAS J. GRAFF, ESQ., Of Counsel ENVIRONMENTAL DEFENSE FUND, INC. 2728 Durant Avenue Berkeley, California 94704 Telephone: 415-548-8906 ORIGINAL FILED JUI1 8, 1972 CLERK, U. S. DIST. COURT SAN FRANCISCO

IN THE UNITED STATES DISTRICT COURT

IN THE NORTHERN DISTRICT OF THE STATE OF CALIFORNIA

Environmental Defense Fund, Inc.; American River Touring Association; Adventures Unlimited; American Guides Association; Duncan Coldwell; Oars, Inc.; Outdoor Unlimited; White- Water Expeditions; Wilderness Water- ways; Wilderness World; River Adventures-West; ECHO-The Wilderness Co.; Pacific Outfitters Association; Gerald Meral; Robert K. Boyden; Dan Schmierer, NO. C-72-1057 plaintiffs, CBR COMPLAINT FOR REVIEW v, OF ADMINISTRATIVE ______ACTION______Ellis Armstrong, Commissioner, Bureau of Reclamation; Rogers Morton, Secretary of the Interior; Robert Froehlke, Secretary of the Amy; General Frederick B. Clarke, Chief of Engineers, United States Army; Colonel Everett E. Love, Acting Division Engineer, Pacific Southwest Division, Army Corps of Engineers,

defendants, ) ______)

Added 21 Jun 72 1. This is a civil action for injunctive and declaratory relief

arising under the National Environmental Policy Act of 1969, 42 U.S.C.

1 4321 et seq. (hereinafter "NEPA").

This Court has jurisdiction over this action by virtue of the provisions of 5 U.S.C. § 782 (Review of Agency Action); 28 U.S.C.

1 1331(a) (Federal Question); 28 U.S.C. i 1337 (Regulation of Commerce);

28 U.S.C. § 1361 (Mandamus); and 28 U.S.C. 1 2201, 2202 (Declaratory

Judgments).

2. Plaintiff Environmental Defense Fund, Inc. (hereafter "EDF"), is a non-profit, public-benefit menbership corporation organized and existing under the laws of the State of New York. It has offices at

East Setauket, New York, Uashington, D. C., and Berkeley, California.

EDF's members are scientists, attorneys and other citizens, over 4,000 of whom reside in California. EDF exists to promote research and action

and to take action on its own behalf and on behalf of its members, to protect and enhance the natural and social environment, including, but

not limited to, the preservation of rivers, river basins, and wildlife,

as well as the maintenance of agricultural resources and the social and economic well-being of persons engaged in agriculture, and to prevent

injuries to itself and to its members caused by degradations to the

natural environment. Under its by-laws, EDF's purposes include "a joining

of the best scientific findings with the most appropriate social action

discovered by the social sciences and legal theory in order [to]. . . best promote a quality environment." 3. Plaintiffs American River Touring Association, Adventures

Unlimited, American Guides Association, Duncan Coldwell, Oars, Inc.,

Outdoors Unlimited, White-Water Expeditions, Wilderness Waterways,

Wilderness World, River Adventures-West, ECHO-The Wilderness Co., and

Pacific River Outfitters Association are engaged in the business of

\ running commercial raft trips for hire on the white-water reaches of the Stanislaus River. As the project here in question will destroy the said white-water reaches, these plaintiffs will no longer be able to conduct such trips, to their damage.

4. Plaintiff Gerald Meral is a resident of Berkeley, California who has on many occasions floated by raft and kayak the Stanislaus

River, the stream to be affected by the project here in question, and has derived aesthetic and other benefits from these experiences. As the project here in question will render such white-water rafting impossible, plaintiff Meral will be injured by its construction.

5. Plaintiff Robert K. Boyden is a resident of Sunnyvale, California who has on many occasions floated by raft the Stanislaus River, and has

derived aesthetic and other benefits from these experiences. As the project in question will render such white-water rafting impossible, plaintiff Boyden will be injured by its construction.

6. Plaintiff Dan SchmLerer is a resident of Columbia, California who owns a gold mining claim located under the mining laws of the United

States which will be destroyed, to his detriment, by the construction

of the project here in question. 7. Defendant Robert Froehlke is Secretary of the Army of the

United States and is an officer of the United States, He is charged by statute with the overseeing of certain civil functions of the

Department of the Army, such as the construction of canals, dikes, dams and the like. Defendant General Frederick B. Clarke is Chief of Engineers,

Corps of Engineers, and is an officer of the United States. lie is charged with overall operational supervision of the work of the Corns of Engineers, United States Army, including its civil functions.

Defendant Everett E. Love is Acting Division Engineer, Corps of Engineers, and the officer of the United States directly responsible for construction of the project here in question.

8. Defendant Rogers Morton is Secretary of the Department of the

Interior of the United States, and an officer of the United States.

He is charged by statute with the ultimate operational and administrative supervision of the Defendant the Bureau of Reclamation, the agency whidi will operate the project here in question, once it is completed.

Defendant Ellis Armstrong is Commissioner of Reclamation, Bureau of

Reclamation, and is an officer of the United States.

9. The authority of all the aforesaid defendants is limited by

NEPA. Accordingly, the defendants must conply with this statute in

respect of the project in question. The individual defendants and their predecessors in office have been and continue to be responsible for

the illegal, unauthorized ultra vires acts hereinafter alleged. Relief is sought against them to enjoin them from further illegal, unauthorized and ultra vires acts and they are therefore joined as defendants in their official capacity.

10. Defendants Morton, Armstrong, Froehlke and Clarke maintain offices, do business and reside in the District of ColunMa. < Defendant ,

Love maintains his office in San Francisco, California. Each may be served by certified mail pursuant to 28 U.S.C. 1391(e), except for defendant Love, who may be served personally.

11. The amount in controversy, exclusive of interest and costs, exceeds $10,000.

12. Venue is properly laid in this District, in that Division

Engineer responsible for this project resides in this District.

13. Certain of EDF's menbers have used and enjoyed the Stanislaus

River in its free-running state by hiking, rafting, canoeing or other activity, but will no longer be able to use and enjoy the river as previously done should the project be constructed as proposed, and they would be injured by the construction of the project as proposed.

14. This suit arises out of a construction project in which defendants Froehlke, Clarke and Love are engaged, known as the New lielones Dam. Althourfi defendants, for reasons hereinafter alleged,

are proceeding illegally, without authority and ultra vires, they purport to justify their activities under the Flood Control Act of

22 Decenber 1944 (P.L. 78-534, 58 Stat. 887) and the Flood Control Act

of 1962 (P.L. 87-874, 76 Stat. 1180). 15. The project in question includes the construction of a 625 foot high rockfill structure on the Stanislaus River; about 60 miles upstream from its confluence with the San Joaquin River. If completed, the dam will impound approximately 2,500,000 acre feet of water. The purported purposes for which the project is to be constructed include flood control, irrigation, power generation, recreation, downstream fisheries enhancement and water quality control.

16. Although the project is being constructed by the Corps of

Engineers, it will be operated by the Bureau of Reclamation and its officers, as a part of the Bureau's overall operation of the Central

Valley Project. The Central Valley Project is a large-scale reclamation project designed to impound water at several locations in Northern

California and transport it to the arid regions of the Central Valley to the south.

17. As the project and its operation will have a significant impact upon the environment, defendants are obliged to comply with the provisions of the National Environmental Policy Act of 1969, 42 U.S.C.

4321 et seq., as follows:

(a) by interpreting the legislation authorizing this project in

accordance with the policies set forth in NEPA;

(b) by utilizing a systematic, interdisciplinary approach to insure

the integrated use of the natural and social sciences in the environ­

mental design arts in planning and in taking decisions in respect of

the project; (c) by giving consideration to environmental amenities and values

in connection with the planning of the project, in addition to

economic and technical considerations;

(d) by studying, developing and describing appropriate alternatives

to the project and its operation as presently conceived.

In addition, defendants are required by NEPA to provide a detailed statement assessing the environmental iirpact of the project which must

include, inter alia, a discussion of alternatives to the project.

GROUNDS FOR RELIEF

18. Defendants, and their predecessors in office, have proceeded and are proceeding with the planning and construction of the project without complying with the statutory requirements set forth above.

19. Plaintiffs have no adequate remedy at law, and unless defendants are restrained by this Court, the project will be completed without

compliance with the requirements of NEPA, to the irreparable damage of plaintiffs.

WHEREFORE, plaintiffs pray for a declaration that defendants have proceeded in the planning and the construction of this project in violation of law, for an injunction forbidding further planning or

construction of the project unless and until defendants comply with the

requirements of the National Environmental Policy Act of 1969, such other

relief as may be just, and for their costs incurred therein.

Michael W. Palmer Attorney for Plaintiffs