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dominated by the buckbean (Menyanthes trifoliata), more common in the Sierra
Nevada and Cascade Mountains of Oregon.
Impacts to Wetlands
A detailed hydrologic study should be conducted using the best available
scientific information to determine the relationship between wetlands of the
Crescent City Marsh Wildlife Area, other adjacent and downstream wetlands, and
those of the Martin Ranch which are immediately adjacent to the area proposed
for development. The best scientific information should be used to determine the
existing subsurface connections and relationships between the various wetlands
in the watershed, and how changes would potentially affect water levels at the
Crescent City Marsh. Information on how the Martin Ranch wetlands are
currently contributing to the recharge and/or storage of subsurface water flowing
to the Crescent City Marsh is crucial information necessary to evaluate potential
direct and cumulative impacts to the western lily and other sensitive species and
habitats. The DEIS should include this information and appropriate hydrologic
studies should be conducted prior to evaluating this proposal.
The DEIS fails to address wetlands that meet the single criterion definition
(hydrology, hydric soils, or hydrophytic vegetation) of wetlands as defined by the
U.S. Fish & Wildlife Service, the California Coastal Commission, and the
California Department of Fish & Game. The environmental consequences should
be revised to assess impacts to all wetlands, rather than limiting the discussion to
wetlands as defined by the U.S. Army Corps of Engineers.
Lack of Information on Hydrological Impacts
The BIA has not provided any hydrological analysis of effects on groundwater
recharge and hydrologic connections between the project site and the Crescent
City Marsh. This lack of information was cited by the California Coastal
Commission staff as a deficiency in the BIA's application for a federal
consistency determination, and remains an outstanding deficiency in the DEIS.
CNPS believes that a review of hydrologic assessments should be conducted by
U.S. Fish & Wildlife Service hydrologists to ensure that jeopardy to the western
lily will not occur as a result of indirect and cumulative impacts related to changes
in the Crescent City Marsh's hydrology. According to the U.S. Fish & Wildlife
Service's letter to the BIA dated January 14, 2003,
A qualified hydrologist should conduct studies to determine the hydrologic
connections and relationships between the development area and the
Crescent City Marsh. Hydrologic and water quality models should be
developed that can predict and evaluate changes in surface and ground
water flows and characteristics to Crescent City Marsh as a result of