United States Department of the Interior

BUREAU OF LAND MANAGEMENT

Carson City Field Office
5665 Morgan Mill Rd.
Carson City, NV 8970 I
(775) 885-6000

File No. 1-5-04-SP-073

Memorandum February 28, 2006

To: Field Supervisor, Nevada Fish and Wildlife Office, Reno, Nevada
(Attn. Marcy Haworth)

From: Manager, Carson City Field Office

Subject: Amended Fish Springs Ranch Biological Assessment

Attached is a Biological Assessment of the affect of my Proposed Action to issue a right-of-way to Fish
Springs Ranch, LLC, for the construction of a pipeline from East Honey Lake Valley to Lemmon Valley
(approximately 28 miles), all in Washoe County, Nevada, along with ancillary facilities. These actions
were analyzed in the Final Environmental Impact statement North Valleys Rights-of-Way Projects
(BLM/CC/ES-05/022) and in the attached Biological Assessment. This amended biological assessment
reflects discussions between Marcy Hayworth and Walt Devaurs, as well as additional hydrological
analysis provided by the project proponent. It is the conclusion of Walt Devaurs, Wildlife Program Lead
for this office, with which I concur, that this action may affect but is not likely to adversely affect the
Carson wandering skipper, Lahontan cutthroat trout, Cui-ui, and bald Eagle or their habitats in the
Action Area.

I am, therefore and hereby, requesting your concurrence with our Biological Assessment. If your
analysis results in a letter of non-concurrence, please advise as to where our logic is flawed or
information gaps exist.

If you have any questions regarding this response, please contact me (775) 885-6151or Walt Devaurs at
(775) 885-6150
 Biological Assessment
For
Fish Springs Ranch, LLC
Water transmission Pipeline portion
Of the
North Valleys Rights-of-Way Projects

Carson City Field Office

Bureau of land Management
Carson City, Nevada
January 24, 2006

INTRODUCTION

The following is a biological assessment (BA) pursuant to the Endangered Species Act,
Section 7(c)(l) which evaluates the effects of the Carson City Field Office, Bureau of
Land Management (BLM), granting a right-of-way to Fish Springs Ranch, LLC, (a
private entity) across public land to allow installation of a pipeline to transport water
from wells located north of Reno. This action was analyzed, along with a similar
proposal by Intermountain Water Supply, Ltd., in the North Valleys Rights-of-Way
Projects Final Environmental hnpact Statement (BLM, 2005), hereinafter referred to as
the Final EIS. Each company is proposing to construct and operate water supply and
transmission projects to meet present and future water demands identified in the Washoe
County Comprehensive Plan - North Valleys Area Plan; specifically, the Proposed Actions
would result in delivery of water to the Stead/Lemmon Valley Area. For purposes of this
BA, the two proposals are considered independent because one but not the other (or either
or both) could be approved for a right-of-way grant.

Fish Springs Ranch and Intermountain Water Supply are two independent water
companies proposing projects in Washoe County, Nevada generally located
approximately 15 to 35 miles north of Reno, Nevada. Each company is proposing to
construct and operate water supply and transmission projects to meet present and future
water demands in the Stead/Lemmon Valley Area encompassed by the North Valleys
Area Plan in Washoe County. The proposed Projects consist of installation and operation
of wellheads, electrical distribution lines, water pipelines, pump stations, surge tanks, and
a terminal water storage tank. Fish Springs Ranch's proposed Project would involve
construction of an electrical substation on private land adjacent to the Alturas 345 kV
transmission line in Honey Lake Valley. Intermountain Water Supply's proposed Project
includes installation of wells and construction of a pump station and storage tanks on
public land.

1
Operation, maintenance, and termination of the proposed facilities may ultimately
become the responsibility of the water purveyor - Washoe County Department of Water
Resources or Truckee Meadows Water Authority- after project construction is
completed and the systems certified.

The Fish Springs Ranch proposal would convey up to 8,000 acre-feet per year (a£'yr) from
six wells located on Fish Springs Ranch property. The proposed pipeline would proceed
south approximately 28 miles from the pump station to the terminal tank site between
Lemmon Valley and Antelope Valley. The futermountain Water Supply proposal would
convey a maximum of 2,000 a£'yr from five wells located in Dry Valley and two in Bedell
Flat. The proposed Intermountain Water Supply pipeline would parallel the Fish Springs
Ranch pipeline in portions of Dry Valley, Bedell Flat, and Antelope Valley and proceed
south approximately 24 miles to a terminus near Stead.

BLM determined that the proposed Projects have the potential to result in "significant
impacts to the environment" and as such, an Environmental hnpact Statement (EIS) was
prepared to ensure compliance with the National Environmental Policy Act (NEPA) of
1969. Due to similar timing, geography, and project type, BLM decided that the two
Plans of Development would be evaluated in the same EIS. A Draft North Valleys
Rights-of-Way Projects EIS was released to the public on May 10, 2005, with a comment
period until July 20, 2005. After the incorporation of the comments received, a Final
North Valleys Rights-of-Way EIS (BLM/CC/ES-05/022) was issued on November 10,
2005.

This Final EIS describes the Proposed Actions and Alternatives (including No Action
Alternative), and environmental consequences that could result from implementation of
these actions. Potential direct, indirect, and cumulative effects on the environment are
analyzed. Impacts described in this EIS will form the basis for a BLM Records of Decision
(ROD) regarding the Proposed Actions, Alternatives, and selection of appropriate
mitigation measures. The RODs will not be issued until necessary permits have been
obtained and requisite consultations have been completed. This Final EIS also forms the
basis for the analysis contained in this biological assessment.

CONSULTATION IDSTORY

There is no consultation history for these projects prior to BLM's initiation of consultation
with Fish and Wildlife Service (USFWS) via a request for a list of threatened, endangered,
proposed, or candidate species that may occur in the action area of the North Valley Rights-
of-Way Projects. USFWS responded by providing a list in March 2004. Based upon the
analysis contained in the Final EIS, this BA assesses the impacts of the proposed action
upon four listed species:
1. Bald Eagle (Haliaeetus leucocephalus) -Threatened
2. Lahontan Cutthroat Trout (Oncorhynchus clarki henshawi) -Threatened
3. Cui-ui (Chasmistes cujus) - Endangered
4. Carson Wandering Skipper (Pseudocopaeodes eunus obscuros)- Endangered

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FISH SPRINGS RANCH PROPOSED ACTION
Fish Springs Ranch is proposing construction of production wells, water collection and
transmission pipelines, pump stations, water storage tanks, electrical substation, and
distribution lines to convey up to a maximum of 8,000 af/yr of water to the
Stead/Lemmon Valley Area. The water transmission pipeline would extend from six
production wells in southeastern Honey Lake Valley southward through Dry Valley,
Bedell Flat, Antelope Valley, to a terminal storage tank at the divide between Antelope
Valley and Lemmon Valley.

Production Wells
Water would be supplied from six new groundwater production wells constructed in
accordance with current standards and designed for maximum efficiency with a
combined pumping rate of 8,000 af/yr or 5,000 gallons per minute (gal/min). Buried 12-
to 24-inch diameter water collection piping would connect individual wells to two
500,000-gallon capacity storage tanks located in the southwest portion of Fish Springs
Ranch. Each well would be controlled via telemetry by water levels in the storage tanks.
Production wells would be gravel packed, constructed with sanitary seals to a depth 100
feet below ground surface, and equipped with water lubricated vertical turbine pumps.
All production wells would be located on property owned by Fish Springs Ranch.

Each wellhead would be enclosed in a masonry block structure meeting current Uniform
Building Code construction standards and Truckee Meadow Water Authority and
Washoe County minimum design requirements. Structures would be constructed on
foundations slightly elevated above surrounding grade to minimize potential for facility
flooding. Each structure would contain above ground piping, shutoff valve, check valve,
flow meter, air release valve, electrical equipment, and telemetry. Structures would be
located on private land and have a footprint approximately 15-feet wide by 20-feet long.

Pipelines

Well Field (Collection) Pipelines

Well field or collection pipelines would consist of a main collection pipe with waterlines
extending to each well. A portion of the collection pipe would be located within the Fish
Springs Road right-of-way. Pipe stubs outside the right-of-way would be located on Fish
Springs Ranch property. The collection pipeline would cross public land betw.een the
groundwater supply wells and pump station. Approximately 10 miles of the main well
field collection pipeline would be required.

Transmission Pipeline
Water would be pumped from the storage tanks in southeastern Honey Lake Valley over
the east flank of the Fort Sage Mountains into Dry Valley, Bedell Flat, and Antelope
Valley. A portion of this pipeline segment (3 miles in Honey Lake Valley, 8 miles in Dry
Valley, and 5 miles in Bedell Flat) would be constructed adjacent to an existing right-of-
way granted for the Tuscarora Gas Pipeline. Near the center of Bedell Flat, the Fish

3
Springs Ranch pipeline would extend south to Antelope Valley where it would follow
Antelope Valley Road within an existing Washoe County right-of-way to the intersection
with Matterhorn Boulevard. The pipeline would parallel Matterhorn Boulevard
southward within the existing right-of-way to a high point where it diverges east across a
section of private property to the terminal storage tank located on public land. This
storage tank location is on the drainage divide between Antelope Valley and Lemmon
Valley. The Fish Springs Ranch water transmission pipeline would extend approximately
28 miles from the pump station in Honey Lake Valley to the terminal storage tank at an
approximate elevation of 5500 feet above mean sea level (ams!).

Pump Station
A pump station would be constructed adjacent to the storage tanks on Fish Springs Ranch
private land in Honey Lake Valley in the SEY-I of Section 33, Township 26 North, Range
18 East, Washoe County, Nevada. The pump station would be designed to pump water
from the adjacent storage tanks at an approximate elevation of 4210 feet ams! over the
east flank of the Fort Sage Mountains at a maximum elevation of 5520 feet amsl. The
pump station would be designed to provide 6,000 gal/min, with a discharge pressure of
670 psi and would include a minimum of six vertical turbine pumps installed in suction·
barrels, an electrical/control room, and chemical feed room. The pump station would be a
masonry block or metal building approximately 60 feet long by 40 feet wide.

A graded level area approximately 100 x 80 feet would be required for the pump station.
Cut and fill slopes would have a maximum slope of 3: 1 horizontal to vertical. An all-
weather surface of compacted aggregate base and crushed rock surface would be
constructed around the facility. A chain link fence with three strands of barbed wire on
top would be constructed around the perimeter of the site. An alarm system notifying
appropriate personnel of unauthorized entry would also be installed at the station.

Electrical Substation
An electrical substation would be constructed on private land by Sierra Pacific Power
Company adjacent to the Altura,s 345 kV transmission line near the pump station. A 24.9
kV powerline would be installed from the electrical substation to the groundwater
extraction wells. The line would be constructed using single pole structures and extend
approximately 10 miles (4 miles across public land/6 miles across private land) to the
groundwater extraction wells.

Surge Tank
A surge suppression facility including a tank with an estimated volume of 150,000
gallons would be located on a one-acre site along the east flank of the Fort Sage
Mountains on public land. The surge tank would be located between 50 and 100 vertical
feet above the high point of the pass west of the distribution line at an approximate
elevation of 5520 feet amsl. A lateral pipeline from the transmission pipeline to the surge
facility would be required. The tank site would have a perimeter chain link fence topped
with three~strand barbed wire. A tank hatch would be fabricated with a lock box for

4
added security and a tank ladder would be constructed in a manner to prevent
unauthorized personnel from climbing the tanks.

Water Storage Tanks

Two 500,000-gallon capacity water storage tanks would be constructed adjacent to the
pump station on Fish Springs Ranch property in Honey Lake Valley. Each tank would be
24-feet tall by 61-feet in diameter constructed of welded steel. The terminal storage tank
would be constructed at a pad elevation of 5510 feet amsl on a hillside between Antelope
Valley and Lemmon Valley, immediately east and near the high point on Matterhorn
Boulevard on public land administered by BLM.

Specific construction and operations specifications, stipulations and requirements for the
production wells, pipeline and ancillary facilities can be found on pages 2-4 through 2-19
of the Final EIS.

Monitoring
Nevada Revised Statutes (NRS) require the monitoring of ground water withdrawal.
Specifically, NRS 534.250 states:
"5. The State Engineer shall require the holder of a pennit to monitor the operation of the project
and the effect of the project on users of land and other water within the area of hydrologic effect of the
project. In determining any monitoring requirements, the State Engineer shall cooperate with all
government entities which regulate or monitor, or both, the quality of water."

The Final EIS (Appendix D) outlines a groundwater monitoring program developed by

the proponents and all of the Cooperating Agencies that were party to the Final EIS. This
monitoring program will be submitted to the State Engineer for inclusion as a stipulation
of the permits necessary for ground water extraction. The State Engineer may accept this
program as written, modify it, or reject it and require something totally different. It is
expected, however, that because the monitoring plan was developed jointly by the
Cooperating Agencies (i.e. U.S Fish and Wildlife Service; US. Bureau ofIndian Affairs;
US. Geological Survey; Sierra Army Depot; Susanville Indian Rancheria; California
Department of Water Resources; California Department ofFish and Game; Lassen
County, California; Washoe County, Nevada; Truckee Meadows Water Authority;
Truckee Meadows Regional Planning Authority; Airport Authority of Washoe County;
City ofReno; City of Sparks; Pyramid Lake Paiute Tribe) the State Engineer will accept
this as the monitoring requirement under NRS 534.250.

5
SPECIES EVALUATIONS

Bald Eagle (Haliaeetus leucocephalus) - Threatened

Status and Description

The bald eagle was listed as endangered on February 14, 1978, in 43 of the 48 contiguous
states and was listed as threatened in Washington, Oregon, Minnesota, Wisconsin, and
Michigan. On July 12, 1995, FWS reclassified the bald eagle from endangered to
threatened throughout its range in the lower 48 states (USFWS 1995). Most recently, on
July 6, 1999, the bald eagle was proposed for delisting (USFWS 1999). This proposal
has not been finalized or withdrawn to date.

The bald eagle is a large, long-lived bird of prey. Adults have dark-brown bodies, white
heads, and white tails. Characteristic adult plumage is not achieved until at least 4 years
of age. Juveniles exhibit a series of plumages before they achieve adult coloration; in
some plumages, the young may resemble adult golden eagles (Aquila chrysaetos).

Habitat and Life History

Bald eagles breed and nest near coasts, rivers, and large lakes with large open areas
(Ehrlich et al. 1998). Nests, constructed oflarge sticks, are often located in the fork of a
tree and deeply lined with fine materials (Ehrlich et al. 1998). Cliff nests range from ·
minimal sticks to massive structures. A monogamous pair usually produces two eggs
(ranges from one to three eggs). Nearly all successful bald eagle nests are within 2 miles
of open water and most are less than 0.5 mile from a river, lake, coastal area, or open bay
(Green 1985; Guilfoyle et al. 2000). Bald eagles feed primarily on fish, small mammals
(especially lagomorphs), waterfowl, seabirds, and carrion (Green 1985; Swenson et al.
1986).

Bald eagles are present in the action area as transient visitors during spring and fall
migrations and as winter residents in Honey Lake Valley and other areas where
permanent open water attracts waterfowl (favored winter prey). Bald eagles also forage in
upland sites for small mammals or feed on livestock or wildlife carrion. No bald eagle
nests or roosts are known to occur in the action area.

Determination of Effects

Direct
Direct effects to bald eagles could include electrocution of individuals by the electrical
distribution power lines planned to power pumps associated with the Fish Springs Ranch
project. However, all powerline construction on lands administered by the Caison City
Field Office is constrained by Standard Stipulations contained in Consolidated Resource
management Plan (BLM 2001), which includes:

6
 "13. Right-of-way holders shall construct, maintain, operate and/or modify
structures or facilities as directed by the Bureau to protect and minimize adverse
effects upon raptors and other wildlife. Raptors will be protected through the use
of "Suggested Practices for Raptor Protection On Powerlines'', Raptor Research
Report No. 4, Raptor research Foundation, Inc. (198l)"(BLM 2001, pg. ROW-5).

Through the use of this Standard Stipulation, the Carson City Field Office has not had a
documented bald or golden eagle electrocution on any of its permitted rights-of-way for
more than twenty years. It is not unreasonable to expect that this will also be the case
with all powerlines and electrical facilities associated with the Proposed Action.

For the portion of the powerline constructed on private lands, the construction standards
used by Sierra Pacific Power Corporation are identical to those used on BLM
administered lands; and this will be stipulated as a condition necessary for approval of the
BLM right-of-way.

Another direct effect associated with the Proposed Action involves a potential reduction
in bald eagle prey base populations (e.g., black-tailed rabbits, cottontail rabbits, and other
small mammals) over the short-term (3 to 5 year period) due to surface disturbance
resulting from pipeline construction activity. The Final EIS identifies the area of surface
disturbance for the Fish Springs Ranch project as 394.7 acres (224.8 acres BLM, 169.9
acres private). Reductions in the prey populations would persist until grass and forbs
become established on the reclaimed corridor. With reestablishment of herbaceous
species on disturbed areas, availability of forage and cover for prey species would equal
or surpass existing conditions. Given that the potential and temporary reduction in habitat
involves only 394. 7 acres of the several hundred thousand acres of adjacent and similar
habitats, it is unlikely that any measurable impacts to bald eagles, on either a local or
regional scale, would be evidenced, and are, therefore Insignificant and Discountable.

Additionally, these upland habitats that will be temporarily lost are surrounded at a
distance by very high quality wetland areas (Washoe Lake, Honey Lake, Lahontan
Reservoir and Lahontan Valley) that provide far superior wintering resources for bald
eagles; and are, in fact, where the majority of the region's bald eagle population winters.

Indirect
A reasonably certain effect resulting from the Proposed Action will be the revegetation of
the pipeline route and other surface disturbances associated with construction of the
ancil1ary facilities. The indirect effect of this upon bald eagles will likely be as
insignificant and discountable a beneficial effect as the temporary loss of this habitat will
be an insignificant and discountable detrimental effect; as discussed above for direct
impacts.

No other indirect impacts arising from the Proposed Action or any interdependent or
interrelated action were identified.

7
Cumulative
The reasonably certain cumulative effects associated with the Proposed Action center in
two areas: 1) how the water imported into the North valleys will be used, and 2) what will
be the disposition of that extra water once it has been used. The first area, how the water
will be used, is discussed in detail in the Final EIS (pages I-7 through I-9), and can be
summarized by stating that the growth to be engendered by this new water has already
been approved at the county and local level. Once the water is available, the build-out
will occur and the expansion of residential and commercial developments will increase
both the density and the extent of the North Valleys growth. It is unlikely, however, that
these increases will affect bald eagle use in the area, which is predominantly spring/fall
migration with one or two birds over-wintering at Swan Lake when there is water in the
playa. The Swan lake playa and associated wildlife habitats have been secured against
further development by the creation of the Swan Lake Nature Study Area (joint BLM,
Nevada National Guard, Washoe County, and City of Reno ownership and management)
and the acquisition of in-holding properties.

The second point, regarding the disposition of effluent waters generated by the Proposed
Action, can only be speculated upon at this juncture. BLM has been approached with
several very tentative and conceptual proposals by various entities regarding the effluent
disposal. These conceptu~l proposals include pumping it to an evaporation area at Bedell
Flat, discharge into the Swan Lake playa, and discharge into the Truckee River. Which
of these options, or of those not yet proposed, is ultimately selected is currently unknown,
but any that do involve the use ofBLM administered lands would be subject to further
environmental analysis and possibly Consultation. What is known is that the discharged
effluent must be in compliance with appropriate federal and state laws and regulations,
and that the permitting process of the Nevada Division of Environmental Protection is an
open and public process. It can only be assumed that if these laws are followed, no injury
to the waters of the State of Nevada or the bald eagle population using those waters in the
area will ensue.

Additional cumulative impacts could arise from the independent construction of the
Intennountain Water Supply water delivery system. This project also entails the
disturbance of both public (141.7 acres) and private (99.2 acres) lands during
construction, with a temporary (3-5 years) loss of potential bald eagle foraging habitat. -A
support infra-structure of electric transmission lines, pumping facilities and other
ancillary structures would also be constructed. As discussed above for the Fish Springs
Ranch project, all powerlines would be constructed to the standards outlined in
"Suggested Practices for Raptor Protection On Powerlines" (Raptor Research Report No.
4, Raptor research Foundation, Inc. 1981), and bald eagle mortality through electrocution
is not anticipated. Similarly, the temporarily disturbed and unavailable potential habitat
(240.9 acres total of all ownerships) will be reclaimed by the reestablishment of
herbaceous species on disturbed areas. Given that the potential and temporary reduction
in habitat involves only 240.9 acres of the several hundred thousand acres of adjacent and
similar habitats, it is unlikely that any measurable impacts to bald eagles, on either a local
or regional scale, would be evidenced.

8
There are additional cumulative effects associated with the Proposed Action, or occurring
in the Action Area that have a lesser degree in their certainty of occurrence, but
nonetheless need to be described. Intermountain Water Supply holds water rights for an
additional 1,000 af/yr of water in upper Dry Valley. In order to exercise this water right,
however, Intermountain Water Supply would need to complete one·or more additional
wells, install additional pipeline, and construct associated infrastructure. Such
development would require acquisition of an amended or new right-of-way across public
land before production of this additional water right could be initiated, along with further
environmental analysis and possible Consultation.

There is also an effort underway involving officials from all levels of government, as
well as private individuals and non-governmental organizations, to draft legislation for
Washoe County along lines similar to the Southern Nevada Public Lands Management
Act. While it is reasonably certain that this will occur, and that it will contain provisions
for disposal of public lands within the Action Area, it is not yet possible to determine the
ultimate disposition of those public lands involved in the Proposed Action.

Determination: The Proposed Action may affect, but is not likely to adversely affect
bald eagles in the project area.

Lahontan Cutthroat Trout (Oncorhynchus clarki henshawi) - Threatened

Status and Description

The Lahontan cutthroat trout, first listed in October 1970, is designated as threatened in
the entire range. It is lmown to occur in Nevada, California, and Oregon. Unless
otherwise cited, the following descriptions of habitat and life-history ofLahontan
cutthroat trout are adapted or excerpted from the Recovery Plan for the Lahontan
Cutthroat trout (USFWS 1995).

The Lahontan cutthroat trout is an inland subspecies of cutthroat trout. Stream-dwelling

fish generally live less than 5 years, and lake dwelling (lacustrine) fish live between 5 and
9 years. Lahontan cutthroat trout feed on terrestrial and aquatic insects. fudividuals can
grow to 15 inches in length.

In 1944, 11 lacustrine populations of Lahontan cutthroat trout occupied about 334,000

acres oflakes, and 400 to 600 fluvial populations occupied over 3,600 miles of streams
within the major basins of Pleistocene Lake Lahontan. Lahontan cutthroat trout currently
occupy between 15 5 and 160 streams totaling approximately 482 miles of occupied
habitat. The subspecies is also found in six lakes and reservoirs, including two small,
wild, indigenous populations in Summit and Independence lakes .. Currently, self-

9
sustaining Lahontan cutthroat trout populations occur in about 11 percent of historic
fluvial and less than 1 percent of historic lacustrinc habitats.

Habitat and Life History

Similar to other trout species, Lahontan cutthroat trout are found in a variety of cold-
water habitats including large terminal alkaline lakes (e.g., Pyramid Lake and Walker
Lake); oligotrophic lakes (e.g., deep, clear lakes with low nutrients and organic matter
and high dissolved oxygen); alpine lakes (e.g., Lake Tahoe and Independence Lake);
slow meandering low gradient rivers (e.g., Truckee, Carson, Walker, and Marys rivers);
and small headwater tributary streams (e.g., Donner Creek and Prosser Creek). Generally,
stream-dwelling Lahontan cutthroat trout occur in cool flowing water with available
cover, velocity breaks, well-vegetated stable stream banks, and relatively silt-free rocky
substrate in riffle-run reaches. Lacustrine Lahontan cutthroat trout populations have
adapted to a wide variety oflake habitats from small alpine lakes to large desert lakes.
Unlike most freshwater fish species, some Lahontan cutthroat trout populations tolerate
alkalinity as high as 3,000 milligrams per liter (mg/L) and total dissolved solids
concentrations up to 10,000 mg/L.

The original strain of Pyramid Lake Lahontan cutthroat trout became extinct in the 1940s
due to diversions of the Truckee River (Sigler and Sigler 1979). Lahontan cutthroat trout
were reestablished in Pyramid Lake through hatchery propagation of strains from
Summit, Walker, and Heenan lakes (Echelle 1991, NatureServe 2005). Historically,
populations in Pyramid and Winnemucca lakes reportedly migrated over 100 miles up the
Truckee River into Lake Tahoe. Today, Lahontan cutthroat trout inhabit Pyramid Lake
and spawn in riffles or tail end pools of the Truckee River. The Derby Dam is a barrier to
upstream spawning runs of Lahontan cutthroat trout.

Within the action area, Lahontan cutthroat trout occur in Pyramid Lake and portions of
the Truckee River. Pyramid Lake is saline, alkaline (pH 9.1 to 9.3 standard units), and
categorized as oligotrophic to mesotrophic (i.e., moderate nutrients, productivity, and
dissolved oxygen concentration). Water depth in the lake has ranged from 365 to 390 feet
since 1981. Pyramid Lake is a monomictic lake (i.e., does not freeze over and has a single
turnover event, "usually in the fall); it may stratify as early as May and typically remains
stratified until December of each year.

Determination of Effects

Direct
As Lahontan cutthroat trout occur in Pyramid Lake and portions of the Truckee River,
and as the Proposed Action contains no construction activities on or adjacent to either
Pyramid Lake or the Truckee River, there will be no direct impacts to the Lahontan
cutthroat trout in Pyramid Lake or the Truckee River.

10
Indirect
The groundwater model for southeastern Honey Lake Valley predicts outflow to Pyramid
Lake Valley via Astor Pass would be reduced by up to about 150 af/yr or 10 percent of
baseline conditions (Final EIS, pg. 4-19). Approximately 1,500 af/yr of groundwater is
estimated to flow naturally from eastern Honey Lake Valley eastward to Pyramid Lake
Valley (Handman et al. 1990). According to Lopes and Evetts of the USGS, total
groundwater recharge in Pyramid Valley is 6,600 af/yr (Lopes and Evetts, 2004). Since
publication of the Final EIS, additional information has been identified which suggests
that the groundwater recharge in Pyramid Lake Valley may be as much as 23,267af/yr
(Lebo, Reuter and Goldman, 1994). The predicted groundwater flow reduction of 150
af/yr to Pyramid Lake Valley from proposed pumping at Fish Springs Ranch, therefore,
may range between 0.6 percent to about 2 percent of total groundwater recharge in
Pyramid Lake Valley.

The model also suggests that groundwater outflow to Smoke Creek Desert via Sand Pass
would be reduced by 570 af/yr or about 11 percent of baseline conditions (Final EIS pg.
4-20). Approximately 5,300 af/yr of groundwater is estimated to flow naturally from
eastern Honey Lake Valley northeastward to Smoke Creek Desert. According to Lopes
amd Evetts of the USGS (Lopes and Evetts, 2004), total natural groundwater recharge in
Smoke Creek Desert is 13,000 af/yr. The predicted groundwater flow reduction of 570
af/yr to Smoke Creek Desert from proposed pumping and Fish Springs Ranch, is about 4
percent of total groundwater recharge to Smoke Creek Desert.

An estimated 2,600 af/yr of groundwater may flow from Smoke Creek Desert to Pyramid
Lake Valley. The proposed pumping at Fish Springs Ranch could eventually reduce this
amount by about 500 af/yr. If this estimated 500 af/yr reduction in Smoke Creek Desert
is added to the estimated groundwater flow reduction through Astor Pass, total
groundwater flow reduction to Pyramid Lake Valley could be 650 af/yr or about 3 to 10
percent of the total groundwater recharge for Pyramid Lake Valley. It is important to
note that the Final EIS further indicates that 95 percent of total groundwater drawdown
would be achieved after 100 years of pumping (Final EIS pg. 419).

The model did not calculate a reduction in groundwater discharge to Pyramid Lake,
which is several miles from the eastern model boundary, merely the groundwater
discharge from eastern Honey Lake Valley into Pyramid Lake Valley. It is not known
how much groundwater flow in Pyramid Valley recharges Pyramid Lake; however, it is
likely that the lake is a major discharge point for groundwater recharged in the
surrounding mountains (Final EIS, pg 4-19).

The computer model used in the North Valleys EIS assumed a flow connection
between Honey Lake Valley and Pyramid Lake Valley as a conservative approach
to evaluate potential impacts due to the proposed project. There is data
that both support and refute whether groundwater flow exits Honey Lake
Valley through the pass. Groundwater flow through Astor Pass to the east is
hypothesized on the basis of water level elevations from wells in the Astor
Pass area. These water levels in the wells are higher than the elevation of Pyramid

11
Lake, suggesting a gradient to the east toward Pyramid Lake Valley. There
are no wells actually located within Pyramid Lake Valley that provide any
data to support this conclusion. An analogous situation exists between
Lake Tahoe and the Truckee Meadows. The elevation of Lake Tahoe is
approximately 6,220 feet compared to an elevation of the Truckee Meadows of
4,400 feet. Although there is a pronounced gradient, the geologic
conditions between the lake and the Reno area do not favor groundwater flow
to the northeast.

Other information suggesting hydraulic communication between Honey Lake

Valley and Astor Pass is found in hydrographs of water levels from
monitoring wells in the pass over the past ten years, suggesting an
influence from pumping in Honey Lake Valley. However, the results of
aquifer stress tests conducted in wells in Astor Pass show the presence of
impermeable boundaries that would prevent flow through the pass into Pyramid
Lake Valley (Nork, 1991). Since there was some ambiguity related to the question of
flow through the pass, a conservative approach was taken in terms of evaluating
potential environmental effects simulated in the model.

Other computer models of Honey Lake Valley, such as the model constructed by
Nancy Moll (Moll, 2000) as well as the Nork model (Nork, 1991),
did not assume flow through Astor Pass. These models were demonstrated to
simulate groundwater conditions in Honey Lake Valley reasonably well.

To simulate the assumed flow through Astor Pass, the EIS groundwater model
prepared for the Fish Springs Ranch project assigned a boundary condition.
This is a simplified mathematical artifice that causes flow to occur from
the model edge at the pass to some defined location outside the model. In
this case, the most obvious location to select outside the model was Pyramid
Lake. It could just as well have been a location closer to or farther from
the pass such as an area of faulting along the mountain front in Pyramid
Lake Valley which would redirect flow away from the lake, or a known area of
evapotranspiration which would act to discharge groundwater, also thereby
redirecting groundwater from the lake. Using Pyramid Lake for this boundary
calculation does not take into account any of these probable influences or
the geologic environment between the pass and the lake. Given the likely influence of
various geologic features between Astor Pass and Pyramid Lake, to assume that all
of the modeled reduction in groundwater flow due to pumping in Honey Lake
Valley flows directly to the lake, and is therefore a 100 percent loss to
the lake, would be unrealistic.

As uncertain as the potential for a reduction in groundwater flow through Astor Pass to
influence Pyramid Lake, the potential for a reduction of gronndwater flow through Sand
Pass to influence Pyramid Lake is even more uncertain. This uncertainty arises from the
fact that any reduction of outflow from Honey Lake Valley to the Smoke Creek Desert
must be propagated through the Smoke Creek Desert hydrographic basin to Pyramid

12
Lake Valley. Given the likely influence of various geologic features between Sand Pass
and Pyramid Lake and the distance involved, to assume that all of the modeled reduction
in groundwater flow due to pumping in Honey Lake Valley flows directly to the lake, and
is therefore a 100 percent loss to the lake,would be unrealistic and without data support.

To put the magnitude of the potential reduction in groundwater inflow to Pyramid Lake
Valley in perspective, the average annual flow of the Truckee River into Pyramid Lake is
approximately 410,000 af/yr for the period of 195 8 to 2002 (Final EIS, page 4-20).
Assuming up to 23,267 af/yr of groundwater recharge to the basin also discharges into
the lake, the potential reduction in groundwater outflow from eastern Honey Lake Valley
of 650 af/yr amounts to 0.15 percent of the total inflow to Pyramid Lake Valley.

According to the American Standards for Testing and Materials (ASTM) D5413-93
(2002), water levels in open water bodies should be measured to the nearest 0.01 feet.
Given the accuracy with which water levels in open bodies of water can be measured, and
the uncertainty as to how much of the groundwater flow exiting eastern Honey Lake
Valley actually reaches Pyramid Lake, the most conservative estimated reduction in
groundwater outflow predicted in the Final EIS does not lend itself to meaningful
measurement, detection or evaluation of such insignificant effects.

As an indication of just how un-meaningful a measurement this would be can be seen in

the following hypothetical analysis:
Assumptions: (1) all of the 650 af/yr potential groundwater loss to Pyramid Lake
Valley does occur; and (2) 100 per cent of this 650 af/yr is lost to Pyramid Lake.

A 650 af/yr loss spread over the 114,000acres of Pyramid Lake

(www.pyramidlakefisheries.com) equates to an annual reduction of 0.0057 feet;
or a full order of magnitude below ATSM thresholds for accurate measurement of
water levels in open water bodies.
These assumptions in no way can be considered representative of actual conditions, but
were used solely to provide an indication of whether or not a meaningful measurement of
change could be made.

It is also important to note that the potential reduction in lake level arising from a
reduction in groundwater inflow to Pyramid Lake Valley modeled in the Final EIS is well
below recent annual variations in lake level for Pyramid Lake. The potential reduction in
groundwater inflow to Pyramid Lake Valley modeled in the Final EIS would therefore
never reach the scale where take of Lahontan cutthroat trout occurs.

No ground water connectivity between the Fish Springs Ranch water delivery proposal
and the Truckee River was identified, therefore there would be no indirect impacts to
Lahontan cutthroat trout in the river.

Cumulative
As Lahontan cutthroat trout occur in Pyramid Lake and portions of the Truckee river, and
as the Final EIS identified no groundwater connectivity between either the Dry valley or

13
Bedell Flat hydrologic basins from which the lntermountain Water Supply Proposed
Action would pump groundwater, there will be no cumulative impacts to the Lahontan
cutthroat trout in Pyramid Lake or the Truckee River..

The cumulative effects associated with the Proposed Action center on the disposal of the
effluent generated by the importation of additional water into the North valleys and these
cumulative impacts, if any, can only be speculated upon at this juncture. BLM has been
approached with several very tentative and conceptual proposals by various entities
regarding the effluent disposal. These conceptual proposals include pumping it to an
evaporation area at Bedell Flat, discharge into the Swan Lake p laya, and discharge into
the Truckee River. Which of these options, or of those not yet proposed, is ultimately
selected is not knowable at this time. What is knowable is that the discharged effluent
must be in compliance with appropriate federal and state laws and regulations. It can
only be assumed that if these laws are followed, no injury to the water quality or quantity
of the Truckee River, with consequent injury to the Lahontan cutthroat trout in Pyramid
Lake and the Truckee River, will ensue.

Determination: The Proposed Action may affect, but is not likely to adversely affect
the Lahontan cutthroat trout in Pyramid Lake.

Cui-ui (Chasmistes cujus) - Endangered

Listed Endangered

Status and Description

The cui-ui was listed as Endangered on March 11, 1967. It is a large plankton-feeding
fish that only occurs in Pyramid Lake and the lower Truckee River, Nevada. A lake
dweller, cui-ui is a stream spawner and the Truckee River is the only perennial tributary
to Pyramid Lake. For most of the twentieth century, cui-ui did not have access from
Pyramid Lake into the Truckee River. Pyramid Lake provides rearing habitat for larvae,
juveniles, and adults. The lower Truckee River provides spawning habitat, with most
spawning occurring between Marble Bluff and Numana dams.

The cui-ui is a large (up to 3.5 kg.) and long-lived (40+ years) lakesucker of the
Catostomidae family. Spawning ranges from as early as April to as late as June,
depending upon timing of runoff, river access, and water temperature. Fertilized eggs
hatch in 1 - 2 weeks. Juveniles feed on zooplankton, particularly cladocerans, copepods
and ostrocods, as well as chironomid larvae, and algae. The juveniles reach maturity in 6
-12 years.

Cui-ui spawn in the shallow gravel beds of the lower Truckee River. The species
inhabited both Pyramid Lake and Winnemucca Lake at the beginning of the 201h Century,
but was eliminated from Winnemucca Lake when it dried completely in the 1930s
following the unrestricted diversion of water from the Truckee River combined with a
severe drought. It is currently found only in Pyramid Lake and the lower Truckee River

14
(downstream from Derby Dam). Adult and juvenile cui-ui reside in Pyramid Lake year-
round.

Surface elevation of Pyramid Lake is currently 80 feet lower than at the beginning of the
20th Century. Structural impediments to fish passage have also been constructed
including Marble Bluff and Numana dams. Adult cui-ui use the lower 12 miles of the
Truckee River only during the spawning season (April to June) and only in years which
there is sufficient attraction flow and passage above or around the delta (Scoppettone
1986).

Determination of Effects

Direct
As Cui-ui occur in Pyramid Lake and portions of the Truckee River, and as the Proposed
Action contains no construction activities on or adjacent to either Pyramid Lake or the
Truckee River, there will be no direct impacts to the Lahontan cutthroat trout in Pyramid
Lake or the Truckee River.

Indirect

The groundwater model for southeastern Honey Lake Valley predicts outflow to Pyramid
Lake Valley via Astor Pass would be reduced by up to about 150 af/yr or 10 percent of
baseline conditions (Final EIS, pg. 4-19). Approximately 1,500 af/yr of groundwater is
estimated to flow naturally from eastern Honey Lake Valley eastward to Pyramid Lake
Valley (Handman et al. 1990). According to Lopes and Evetts of the USGS, total
groundwater recharge in Pyramid Valley is 6,600 af/yr (Lopes and Evetts, 2004). Since
publication of the Final EIS, additional information has been identified which suggests
that the groundwater recharge in Pyramid Lake Valley may be as much as 23,267 af/yr
(Lebo, Reuter and Goldman, 1994). The predicted groundwater flow reduction of 150
af/yr to Pyramid Lake Valley from proposed pumping at Fish Springs Ranch, therefore,
may range between 0.6 percent to about 2 percent of total groundwater recharge in
Pyramid Lake Valley.

The model also suggests that groundwater outflow to Smoke Creek Desert via Sand Pass
would be reduced by 570 af/yr or about 11 percent of baseline conditions (Final EIS pg.
4-20). Approximately 5,300 af/yr of groundwater is estimated to flow naturally from
eastern Honey Lake Valley northeastward to Smoke Creek Desert. According to Lopes
amd Evetts of the USGS (Lopes and Evetts, 2004), total natural groundwater recharge in
Smoke Creek Desert is 13,000 af/yr. The predicted groundwater flow reduction of 570 .
af/yr to Smoke Creek Desert from proposed pumping and Fish Springs Ranch, is about 4
percent of total groundwater recharge to Smoke Creek Desert.

An estimated 2,600 af/yr of groundwater may flow from Smoke Creek Desert to Pyramid
Lake Valley. The proposed pumping at Fish Springs Ranch could eventually reduce this
amount by about 500 af/yr. If this estimated 500 af/yrreduction to Smoke Creek Desert is
added to the estimated groundwater flow reduction through Astor Pass, total groundwater
flow reduction to Pyramid Lake Valley could be 650 af/yr or about 3 to 10 percent of the

15
total groundwater recharge for Pyramid Lake Valley. It is important to note that the Final
EIS further indicates that 95 percent of total groundwater drawdown would be achieved
after 100 years of pumping (Final EIS pg. 419).

The model did not calculate a reduction in groundwater discharge to Pyramid Lake,
which is several miles from the eastern model boundary, merely the groundwater
discharge from eastern Honey Lake Valley into Pyramid Lake Valley. It is not known
how much groundwater flow in Pyramid Valley recharges Pyramid Lake; however, it is
likely that the lake is a major discharge point for groundwater recharged in the
surrounding mountains (Final EIS, pg 4-19).

The computer model used in the North Valleys EIS assumed a flow connection
between Honey Lake Valley and Pyramid Lake Valley as a conservative approach
to evaluate potential impacts due to the proposed project. There is data
that both support and refute whether groundwater flow exits Honey Lake
Valley through the pass. Groundwater flow through Astor Pass to the east is
hypothesized on the basis of water level elevations from wells in the Astor
Pass area. These water levels in these wells are higher than the elevation of Pyramid
Lake, suggesting a gradient to the east toward Pyramid Lake Valley. There
are no wells actually located within Pyramid Lake Valley that provide any
data to support this conclusion. An analogous situation exists between
Lake Tahoe and the Truckee Meadows. The elevation of Lake Tahoe is
approximately 6,220 feet compared to an elevation of the Truckee Meadows of
4,400 feet. Although there is a pronounced gradient, the geologic
conditions between the lake and the Reno area do not favor groundwater flow
to the northeast.

Other information suggesting hydraulic communication between Honey Lake

Valley and Astor Pass is found in hydro graphs of water levels from
monitoring wells in the pass over the past ten years, suggesting an
influence from pumping in Honey Lake Valley. However, the results of
aquifer stress tests conducted in wells in Astor Pass show the presence of
impermeable boundaries that would prevent flow thro~ the pass into Pyramid
Lake Valley (Nork, 1991 ). Since there was some ambiguity related to the question of
flow through the pass, a conservative approach was taken in terms of evaluating
potential environmental effects simulated in the model.

Other computer models of Honey Lake Valley, such as the model constructed by
Nancy Moll (Moll, 2000) as well as the Nork model (Nork, 1991),
did not assume flow through Astor Pass. These models were demonstrated to
simulate groundwater conditions in Honey Lake Valley reasonably well.

To simulate the assumed flow through Astor Pass, the EIS groundwater model
prepared for the Fish Springs Ranch project assigned a boundary condition.
This is a simplified mathematical artifice that causes flow to occur from
the model edge at the pass to some defined location outside the model. In

16
this case, the most obvious location to select outside the model was Pyramid
Lake. It could just as well have been a location closer to or farther from
the pass such as an area of faulting along the mountain front in Pyramid
Lake Valley which would redirect flow away from the lake, or a known area of
evapotranspiration which would act to discharge groundwater, also thereby
redirecting groundwater from the lake. Using Pyramid Lake for this boundary
calculation does not take into account any of these probable influences or
the geologic environment between the pass and the lake. Given the likely influence of
various geologic features between Astor Pass and Pyramid Lake, to assume that all
of the modeled reduction in groundwater flow due to pumping in Honey Lake
Valley flows directly to the lake, and is therefore a 100 percent loss to
the lake, would be unrealistic and without data support.

As uncertain as the potential for a reduction in groundwater flow through Astor Pass to
influence Pyramid Lake, the potential for a reduction of groundwater flow through Sand
Pass to influence Pyramid Lake is even more uncertain. This uncertainty arises from the
fact that any reduction of outflow from Honey Lake Valley to the Smoke Creek Desert
must be propagated through the Smoke Creek Desert hydrographic basin to Pyramid
Lake Valley. Given the likely influence of various geologic features between Sand Pass
and Pyramid Lake and the distance involved, to assume that all of the modeled reduction
in groundwater flow due to pumping in Honey Lake Valley flows directly to the lake, and
is therefore a 100 percent loss to the lake, would be unrealistic

To put the magnitude of the potential reduction in groundwater inflow to Pyramid Lake
Valley in perspective, the average annual flow of the Truckee River into Pyramid Lake is
approximately 410,000 af/yr for the period of 1958 to 2002 (Final EIS, page 4-20).
Assuming up to 23,267 af/yr of groundwater recharge to the basin also discharges into
the lake, the potential reduction in groundwater outflow from eastern Honey Lake Valley
of 650 af/yr amounts to 0.15 percent of the total inflow to Pyramid Lake Valley.

According to the American Standards for Testing and Materials (ASTM) 05413-93
(2002), water levels in open water bodies should be measured to the nearest 0.01 feet.
Given the accuracy with which water levels in open bod.ies of water can be measured, and
the uncertainty as to how much of the groundwater flow exiting eastern Honey Lake
Valley actually reaches Pyramid Lake, the most conservative estimated reduction in
groundwater outflow predicted in the Final EIS does not lend itself to meaningful
measurement, detection or evaluation of such insignificant effects.

As an indication of just how un-meaningful a measurement this would be can be seen in

the following hypothetical analysis:
Assumptions: (1) all of the 650 af/yr potential groundwater loss to Pyramid Lake
Valley does occur; and (2) 100 per cent of this 650 af/yr is lost to Pyramid Lake.

A 650 af/yr loss spread over the 114,000acres of Pyramid Lake

(www.pyramidlakefisheries.com) equates to an annual reduction of0.0057 feet,

17
 or a full order of magnitude below ATSM thresholds for accurate measurement of
water levels in open water bodies.
These assumptions in no way can be considered representative of actual conditions, but
were used solely to provide an indication of whether or not a meaningful measurement of
change could be made.

It is also important to note that the potential reduction in lake level arising from a
reduction in groundwater inflow to Pyramid Lake Valley modeled in the Final EIS is well
below recent annual variations in lake level for Pyramid Lake and that the population of
Cui-ui has been increasing within said variation in lake level. The potential reduction in
groundwater inflow to Pyramid Lake Valley modeled in the Final EIS would therefore
never reach the scale where take of Cui-ui occurs ...

Cumulative
As Cui-ui occur only in Pyramid Lake and the Lower Truckee River, and as the Final EIS
identified no groundwater connectivity between either the Dry valley or Bedell Flat
hydrologic basins from which the Intermountain Water Supply Proposed Action would
pump groundwater, there will be no cumulative impacts to the Cui-ui in Pyramid Lake or
the Truckee River arising from the Intermountain Water Supply project..

The cumulative effects associated with the Proposed Action center on the disposal of the
effluent generated by the importation of additional water into the North valleys and these
cumulative impacts, if any, can only be speculated upon at this juncture. BLM has been
approached with several very tentative and conceptual proposals by various entities
regarding the effluent disposal. Any proposal carried forward that uses or crosses public
lands would need to be analyzed for impacts and a Consultation conducted if necessary.
These conceptual proposals include pumping it to an evaporation area at Bedell Flat,
discharge into the Swan Lake playa, and discharge into the Truckee River. Which of
these options, or of those not yet proposed, is ultimately selected is not knowable at this
time. What is knowable is that the discharged effluent must be in compliance with
appropriate federal and state laws and regulations. It can only be assumed that if these
laws are followed, no injury to the water quality or quantity of the Truckee River, with
consequent injury to the Cui-ui in Pyramid Lake and lower Truckee River, will ensue.

Determination: The Proposed Action may affect, but is not likely to adversely affec~
the Cui-ui in Pyramid Lake or the Truckee River.

Carson Wandering Skipper (Pseudocopaeodes eunus obscurus) -

Endangered
Status and Description

The Carson wandering skipper (Pseudocopaeodes eunus obscurus) is a small orange

butterfly and is an obligate of inland salt grass (Distichlis spicata) habitats in Nevada and

18
California. It is a rare species with pronounced habitat specialization. Four populations
are known: Honey Lake Valley, California; Winnemucca Valley, Nevada; Spanish
Springs north of Sparks, Nevada; and Vicky Lane south of Carson City, Nevada. The
subspecies is considered extirpated from a site in Carson City near the juncture of US
Highway 50 and the new Carson City bypass to US Highway 395. It was listed in its
entire range by way of an emergency listing in 2001 (USFWS 2001) followed by a final
rule with listing as an endangered species in 2002 (USFWS 2002).

Habitat and Life History

Carson wandering skipper habitat is characterized as a lowland grassland habitats on

alkaline substrates. Occupied areas are located in a small region of northwestern Nevada
and northeastern California and are characterized by being east of the Sierra Nevada at an
elevation of less than 5,000 feet, with a presence of salt grass and nectar sources, in open
areas near springs or water, and possibly associated with geothermal activity.

Little is know about the life cycle of the Carson wandering skipper, although it is
presumed to be similar to other species in the same family - Hcspcriidae (USFWS 2002).
The Carson wandering skipper may differ from other P. eunus subspecies in producing
only one brood per year during June to mid-July (Austin and Emmel 1998; cited in
USFWS 2002).

A detailed understanding of habitat requirements remains unclear, though some general

habitat characteristics are known. The Carson wandering skipper is found only in or near
salt grass communities and larvae feed exclusively on salt grass (Scott 1986; Brossard et
al. 1999). Characteristics of suitable habitat are suggested by elements common to
known, occupied sites: elevation less than 5,000 feet; located east of the Sierra Nevada
mountain range; presence of salt grass; open areas near springs, seeps, or water; and
geothermal areas (USFWS 2002).

Brossard et al. (1999) offers four hypotheses of Carson wandering skipper microhabitat.
First, suitable habitat is likely related to elevation of the water table. Many salt grass
areas are inundated with water during the spring and butterfly larvae are not known to
develop under water. Therefore, survival of larvae in wet years is dependent on subtle
topographic variation in habitat (i.e., islands of salt grass above water table). In dry years,
larval survival is probably related to timing of host plant senescence. Micro-topographic
variation is probably important for larval survival because it provides a greater variety of
appropriate habitat over time and across varied annual hydrologic conditions. Second,
Carson wandering skipper is almost always observed when they are taking nectar.
Therefore, nectar availability is an important habitat element. Third, butterflies may ·
assess habitat quality as positively related to local density of conspecifics (Brossard et al.
1974). This phenomenon results in concentrations of individuals in particular areas and
potential for underestimation of extent of suitable habitat as assessed by local abundance
or detection of presence. Fourth, because the few historic collections of Carson
wandering skipper have been made at or near hot springs, it is possible that the skipper
may need higher ground or water temperatures associated with these sites for successful
larval development.

19
Many butterfly species are far less selective with regard to nectar sources than they are
about larval host plants and the Carson wandering skipper is no exception (Brussard et al.
1999). Very few plants that grow in alkaline soil that supports salt grass can serve as
nectar sources for Carson wandering skipper. For a salt grass area to be suitable habitat,
at least one nectar-producing plant must be present and in bloom during the flight season
(approximately mid-June to mid-July) (Brossard et al. 1999). One alkaline tolerant nectar
source plant is Thelypodiurn crispum (crisped thelypody; in the Brassica family) though
its distribution is limited in western Nevada. In the absence of T. crispum or another
appropriate alkaline tolerant species, a salt grass area may be suitable habitat for the
Carson wandering skipper only if it contains enough freshwater to support alkaline
tolerant plants nearby (Brassard et al. 1999). Though nectar sources for Carson
wandering skipper likely vary among seasons and localities, the species is entirely
dependent upon salt grass as a larval host (Brossard et al. 1999).

Site surveys of the pipeline routes and areas potentially affected by the drawdown of
groundwater, conducted in 2004 (Sanford 2004), found a single Carson wandering
skipper was observed at East Alkali Flat, in eastern Honey Lake Valley, Nevada (near
Fish Springs Ranch). It is not known if this location supports a temporary population, a
viable long-term population, or ifthe individual observed was an erratic occurrence. No
follow-up inventory has been conducted.

There is, however, an important site near the pipeline route and proposed well fields
known to support a population of Carson wander skipper along Winnemucca Ranch Road
in Warm Springs Valley, located immediately east of Dry Valley and Bedell Flat. A total
of 243 acres in Winnemucca Valley was designated as an Area of Critical Environmental
Concern (ACEC) in the Final Southern Washoe County Urban Interface Plan
Amendment (BLM 2001), with the provision that any additional adjacent Carson
wandering skipper habitat acquired would be incorporated into the ACEC. In 2005, the
remaining 80 acres of known occupied habitat was acquired by BLM, along with 25 acre-
feet of groundwater rights for maintenance and enhancement of that habitat. Because of
the funding mechanism by which these lands were acquired (Southern Nevada Public
Lands Management Act), these lands will remain in public ownership in perpetuity unless
otherwise directed by an act of congress. Current threats to the Winnemucca Valley
population include encroaching development and groundwater drawdown from increased
number of domestic wells in the area (Brossard et al. 1999).

Determination of Effects

Direct
All areas that would be disturbed during implementation of the Proposed Action were
surveyed (Sanford 2004) for the presence of Carson wandering skipper habitat and
populations. Neither was documented. In the absence of either suitable habitat or Carson
wandering skipper populations, there can be no direct impacts.

20
Indirect
The possible indirect effects of the Proposed Action on Carson wandering skipper habitat
and populations center on the effects of groundwater pumping upon the movement and
elevation of the subsurface waters. For the Fish Springs Ranch pumping, this involves
the well field in East Honey Lake Valley. Sanford (2004) found a single Carson
wandering skipper was observed at East Alkali Flat, in eastern Honey Lake Valley,
Nevada (near Fish Springs Ranch). It is not known if this location supports a temporary
population, a viable long-term population, or if the individual observed was an erratic
occurrence. No follow-up inventory has been conducted.

There is little doubt that pumping by Fish Springs Ranch will lower the groundwater
level underneath the skipper sighting locale at East Alkali Flat, but whether or not this
will affect the salt grass habitat is more problematic. Salt grass is a rhizomatous species
with a relatively shallow rooting depth, usually less than six inches. It is typical of the
alkaline and alkaline/saline soils that develop on and around intermittent playa lakes,
where snow melt and/or spring precipitation is kept at or near the soi] surface during the
growing season by a restrictive layer of fine clays below the soil. It is also found in
alkaline soils where no restrictive layer exists, but where moisture is provided by seeps or
springs. In the first instance connectivity with groundwater is unlikely and the presence
or absence of salt grass is a function of winter and spring precipitation. For the second
instance connectivity with groundwater is obvious and the presence of salt grass is
dependent on the presence of the spring or seep.

No springs or seeps were identified as being in East Alkali Flat, and from photographs
and field tour observations the salt grass community is likely dependent on the water that
collects during the winter and spring over a restrictive clay layer. This would indicate a
lack of connectivity between the groundwater and the surface water maintaining the salt
grass community, and it is, therefore, unlikely that groundwater pumping will affect the
continued existence of what may (or may not) be habitat for the Carson wandering
skipper at East Alkali Flat.

Cumulative
Potential Carson wandering skipper habitat within the area affected by groundwater
pumping in Dry Valley, including springs and seeps without salt grass present, were
surveyed (Sanford 2004) with negative results. Therefore, pumping 2,000 af/yr from the
Dry Valley wells would have no indirect impacts on populations or habitat that does not
exist there.

The Final EIS (pg. 4-28) points out that it is possible for pumping in Dry Valley to reduce
groundwater outflow to Warm Springs Valley via the Walker Lane fault zone. However,
using the same argument presented (Interflow Hydrology 2005a; Berger, et al. 2004) to
discount subsurface flow into Honey Lake Valley (i.e. absence of springs along the fault
zone) would also indicate that there is not movement through the fault zone into Warm
Springs Valley, or that ifthere is movement in that direction it is not enough to generate
any surface expression. It is, therefore, concluded that groundwater pumping in Dry

21
Valley would not indirectly affect the Carson wandering skipper population in Warm
Springs Valley.

Potential Carson wandering skipper habitat within the area affected by groundwater
pumping in Bedell Flat, including springs and seeps without salt grass present, were
surveyed (Sanford 2004) with negative results. Therefore, pumping 500 af/yr from the
Bedell Flat wells would have no indirect impacts on populations or habitat that does not
exist there.

Unlike Dry Valley, there is groundwater connectivity between Bedell Flat and Warm
Springs Valley with it known population of Carson wandering skippers at Winnemucca
Ranch Road. Groundwater models in the Final EIS (pg. 4-36) indicate a reduction of 160
af/yr of subsurface flow from Bedell Flat into Warm Springs Valley. This amounts to a
3% reduction of natural groundwater recharge to Warm Springs Valley; and while this
may affect both the habitat and the population of Carson wandering skippers in Warm
Springs Valley, the magnitude of the affect is not known. However, actions taken to date
and currently underway by BLM with regards to the Winnemucca Ranch Road
population are considered by BLM sufficient to protect and enhance this population
irrespective of the minor loss in groundwater recharge from Bedell Flat. These actions
are:
• Designation oflmown habitat as an ACEC (2001)
• Exclusion of grazing except as a habitat enhancement tool (2002)
• Closure of the area to mining claims, leases and material sales (2001)
• Protective fencing of potential habitat adjacent to known habitat (2002)
• Acquisition of 80 acres of known habitat and inclusion of this acquired property
into the ACEC with all restrictions previously applied to ACEC(2005)
• Acquisition of 25 acre-feet of ground water rights for the maintenance and
enhancement of the habitat in the ACEC (2005)
• Fencing of acquired lands (commencing 2006)
• Perfecting water rights (commencing 2006)

Additionally, BLM currently has a contributed funds account (current balance $170,000)
established for the protection and enhancement of the Carson wandering skipper habitat
and population at Winnemucca Ranch Road. Taking all of the above into consideration,
BLM considers the Winnemucca Ranch Road population secure and not likely to be
subject to any indirect impacts arising from the groundwater pumping in Bedell Flat.

Determination
The Proposed Action may affect, but is not likely to adversely affect the Carson
wandering skipper habitats or populations located within the action area.

Determination Summary
Bald Eagle (Haliaeet11s leucocephalus) - Threatened
The Proposed Action may affect, but is not likely to adversely affect bald eagles in the

22
 project area.

Lahontan Cutthroat Trout (011corhynchus clarki henshawz)-Threatened

The Proposed Action may affect, but is not likely to adversely affect the Lahontan
cutthroat trout in Pyramid Lake.

Cui-ui (Chamistes cujus)-Endangered

The Proposed Action may affect, but is not likely to adversely affect the Cui-ui
in Pyramid Lake.

Carson Wandering Skipper (Pseudocopaeodes eunus obscurus) - Endangered

The Proposed Action may affect, but is not likely to adversely affect the Carson
wandering skipper habitats or populations located within the action area.

Prepared By: _ _ __ _ __ _ _ __ _ _ __
Walter R. Devaurs, Wildlife Biologist

Date: - - - - - - - - -

Reviewed & Approved By: _ _ _ _ _ _ _ _ _ __ _ __ _ __ __ __ _

Donald T. Hicks, Field Manager, Carson City

Date:
- - - - -- - ---

23
REFERENCES

Austin, G. T. and J. F. Emmel. 1998. New subspecies of butterflies (Lepidoptera)

from Nevada and California. Chapter 42 in Systematics of western North
American butterflies. T. C. Emmel, ed. Mariposa Press, Gainesville, FL. 878
pp.

Berger, D.L., D. K. Maurer, T.J. Lopes, and K.J. Halford. 2004. Estimates of
Natural Ground-Water Discharge and Characterization of Water Quality in
Dry Valley, Washoe County, West-Central Nevada, 2002-2003. U.S.
Geological Survey, Scientific Investigations Report 2004-5155. Prepared in
cooperation with Washoe County.

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