American River Watershed Institute

wwwARWlus 501(c)(3) EducationResearch

Otis Wollan President otiswollangmailcom (530) 320-6841

Gary Estes SecretaryTreasurer 4135 Eagles Nest Auburn CA 95603 (530) 889-9025

Board of Directors

Gary Estes Founder CA Extreme Precipitation Symposium

Shawna Martinez Biology Dept Chair and Watershed Ecosystem Technician Program Director Sierra College

Saad M Merayyan PhD Associate Professor Water Resources Engineering Civil Engineering Dept California State University Sacramento

Alan Shuttleworthn Professor Emeritus Sierra College

Will Stockwin Mayor and Councilmember City of Colfax

Otis Wollan Consultant Former 5 term PCWA Director Dist 5

pg 1

To California Water Commission

From Otis Wollan former 5-term elected Director District 5 Placer County Water Agency and ARWI President

RE Centennial Dam Proposal for Proposition 1 Funding Date 18 January 2018

Thank you for this opportunity for written public input

As a former five term Director on the Placer County Water Agency for over twenty years I would like to address my written comments to what I believe is a fundamental flaw in the Public Benefits Ratio analysis of the Centennial Dam Proposal

This proposal is piecemealed in that it is submitted as a recreation project and an ecosystem improvement project two components of a dam proposal It is not submitted as a whole multi-purpose dam proposal Its costs impacts and benefits are narrowly limited to those two purposes of a multi-purpose dam The Commission is not getting a complete picture

Because the DEIR for this project is not expected until Fall 2018 your decision-making process will not be informed by a whole project analysis

Heres why a complete picture is crucial for understanding this project proposal

Camp Far West is the 100000 acre-foot reservoir below the proposed Centennial Dam Camp Far West was built in the early 1960s in part with State funding The SWRCB hydrology for the water rights of Camp Far West noted that the reservoir would have spilled in only 18 of the previous 35 years roughly half the water years between 1930 and 1965

The proposed Centennial Dam is 115000 acre feet or 15 larger than Camp Far West As Centennial will be located upstream of Camp Far West Centennial will spill only half the time in that same 35-year period Thus it will effectively deshywater Camp Far West in half the water years

To get the picture on the negative effects of dewatering Camp Far West you have to look at the water rights process before the State Water Resources Control Board South Sutter Water District which built Camp Far West in part with State funds has formally protested this Centennial Dam water rights application because they would be fatally harmed by the dewatering of their reservoir Negotiations have gone nowhere in the four extensions the State Board has granted for the protest resolution This is a

ARWI Comments on SIP to ewe

fundamental dispute about senior rights and a fight for the viability of Camp Far West

The consequences of dewatering Camp Far West are serious First farmers will not have a source of surface water and most of them will turn back to groundwater to grow their crops This will be costly But even more significantly it will return the American River Groundwater Subbasin to the overdraft condition that was the justification for building Camp Far West 50 years ago Camp Far West was built for the purpose of relieving the overdraft of the American River Groundwater Subbasin that underlies Placer Sutter and Sacramento Counties The overdraft was so serious at that time that groundwater levels below Lincoln were dropping 1 frac12 to 3 feet per year The State of California has recently elevated its goals for sustainable groundwater management to the highest level Investment of State taxpayer money in Centennial will both undermine directly the State taxpayer funded Camp Far West and also undermine the States groundwater sustainability goals The Commission needs to look at the SWRCB water rights process to deepen its understanding of the impacts of Centennial Dam The Commission will discover

bull South Sutter Water District has filed a protest to the State Board for NIDs application for water rights to protect its current benefiial use of agricultural irrigation water But note that other beneficial uses like recreation and ecosystem benefits from Camp Far West will also be harmed

bull The County of Placer and Placer County Water Agency have filed protests to NIDs water rights application before SWRCB specificly to protect their goals of groundwater sustainability in the American River Groundwater Subbasin

bull The US Bureau of Reclamation California Department of Fish amp Wildlife and Contra Costa Water District have filed protests to NIDs water rights application for its negative impacts to the Delta Ecosystem and downstream diverters

These downstream negative impacts are not noted in NIDs application

The comprehensive analysis of impacts for this process will be completed in the CEQA Final Environmental Impact Statement The DEIR is scheduled for Fall 2018 There will certainly be extensive comments and legal challenges to this project that will delay the FEIR into 2019 and possibly into 2020 The Commission should question the wisdom of investing State funds in this project until there is a full project description with a full and unchallenged impacts analysis

In addition the recreation and ecosystem benefits made by NID are not being proposed in a balanced way and in fact are creating winners and losers Conflicts are arising between Placer and Nevada Counties The City of Colfax is raising economic and social justice issues The accompanying letters from Placer County Supervisor Jennifer Montgomery and Colfax Mayor Will Stockwin identify some of the disputes that are emerging from the project descriptions that have been released to date Again I urge the Commission to wait for the FEIR in order to fully evaluate this project

I urge the Commission to continue to provide opportunities for public and stakeholder input so that you can be more fully informed about the diverse perspectives about the project proposals that you are contemplating for public funding

ARWI is currently developing an opinion paper focused on the impacts to Placer County Please find attached the current opinion paper that identifies project impacts specific to Placer County Again thank you for the opportunity to provide background and input to this process

pg 2 ARW Comments on WSIP to ewe

DRAFT DRAFT DRAFT DRAFT DRAFT American River Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 1 of8

Potential Centennial Dam Project Impacts to Placer County NOTE The following list is a draft compilation of issues that directly affect Placer County To date little

information has been released on impacts of the Centennial Dam project Several individual construction

feasibility studies have been done by NID including dam construction options Dog Bar Bridge options

the Association of California Water Agencies (ACWA) Integrated Storage study and the application for

funding to the California Water Commission Some impacts have been described in these documents The

detailed analysis of the project in the CEQA Draft Environmental Impact Report is scheduled for release

Fall 2018 so most questions and impacts will not be addressed by NID until that time

However there is adequate _information available at this time from these various project

descriptions to begin assessing impacts and specifically in this white paper the impacts to Placer

County It is the perception on the Placer County side of the Bear River that NID is giving short shrift to

the concerns and interests of Placer County Early scoping meetings were not held in Placer County

Placer County above the elevation of Auburn are not served by NID The eastern foothill portion of

Placer County south of the Bear River is not within the jurisdiction of NID In this location the Bear River is the jurisdictional boundary between Placer and Nevada Counties and NID does not serve the

Placer side of the river above 1200eet elevation (approximation) Thus there is no representation on the

NID Board for any of the Placer County areas directly and indirectly impacted by the project

This paper is a work in progress and will be continually updated as information becomes available

Eventually this paper will be comments to the CEQA DEIR Fall 2018 The issue categories used in this

draft are for the most part consistent with CEQA EIR categories

Principal author of the opinion paper is Otis Wollan ARWI Bear River Awakening Project Manager

with consultation and contributions from the Foothills Water Network the AuburnMeadow Vista-based

Friends of the Bear River Colfax-based Bear River Action Team and citizens of Calf axWeimar ApplegateMeadow Vista area

Water Rights Water Security

1 Centennial Dam Project harms South Sutter Water District( SSWD) and Camp Far West (CFW) NID claims senior water rights over South Sutter Water Districts current storage and usage of Camp Far West NIDs claim is that their original water rights filing for the 1926 Parker Dam that was never built trumps SSWDs water right for Camp Far West which actually did get built and actually has used its water right to full beneficial use every year since it was built in 1963 SSWD has filed a protest against NIDs water rights application to the State Water Resources Control Board So far negotiations between NID and SSWD have failed to resolve this issue IfNID is successful in its application to receive senior water rights from SWRCB and Centennial is allowed to fill before CFW serious shortages will cause several layers of negative impact (see issue paper httpwwwsavebearrivercomup1oads473847384675otiswo11an-parkerdam campfarwestspillspdf )

o CFW supplies roughly 40 of the water used by farmers in SSWD delivered in both Sutter and Placer Counties If Centennial is built in many water years CFW will have only runoff from Wolf Creek drainage and no runoff from the Bear River Serious shortfall of water in CFW will harm Placer County farmers

DRAFT DRAFT DRAFT DRAFT DRAFT American River Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 1 of8

Potential Centennial Dam Project Impacts to Placer County NOTE The following list is a draft compilation of issues that directly affect Placer County To date little

information has been released on impacts of the Centennial Dam project Several individual construction

feasibility studies have been done by NID including dam construction options Dog Bar Bridge options

the Association of California Water Agencies (ACWA) Integrated Storage study and the application for

funding to the California Water Commission Some impacts have been described in these documents The

detailed analysis of the project in the CEQA Draft Environmental Impact Report is scheduled for release

Fall 2018 so most questions and impacts will not be addressed by NID until that time

However there is adequate _information available at this time from these various project

descriptions to begin assessing impacts and specifically in this white paper the impacts to Placer

County It is the perception on the Placer County side of the Bear River that NID is giving short shrift to

the concerns and interests of Placer County Early scoping meetings were not held in Placer County

Placer County above the elevation of Auburn are not served by NID The eastern foothill portion of

Placer County south of the Bear River is not within the jurisdiction of NID In this location the Bear River is the jurisdictional boundary between Placer and Nevada Counties and NID does not serve the

Placer side of the river above 1200eet elevation (approximation) Thus there is no representation on the

NID Board for any of the Placer County areas directly and indirectly impacted by the project

This paper is a work in progress and will be continually updated as information becomes available

Eventually this paper will be comments to the CEQA DEIR Fall 2018 The issue categories used in this

draft are for the most part consistent with CEQA EIR categories

Principal author of the opinion paper is Otis Wollan ARWI Bear River Awakening Project Manager

with consultation and contributions from the Foothills Water Network the AuburnMeadow Vista-based

Friends of the Bear River Colfax-based Bear River Action Team and citizens of Calf axWeimar ApplegateMeadow Vista area

Water Rights Water Security

1 Centennial Dam Project harms South Sutter Water District( SSWD) and Camp Far West (CFW) NID claims senior water rights over South Sutter Water Districts current storage and usage of Camp Far West NIDs claim is that their original water rights filing for the 1926 Parker Dam that was never built trumps SSWDs water right for Camp Far West which actually did get built and actually has used its water right to full beneficial use every year since it was built in 1963 SSWD has filed a protest against NIDs water rights application to the State Water Resources Control Board So far negotiations between NID and SSWD have failed to resolve this issue IfNID is successful in its application to receive senior water rights from SWRCB and Centennial is allowed to fill before CFW serious shortages will cause several layers of negative impact (see issue paper httpwwwsavebearrivercomup1oads473847384675otiswo11an-parkerdam campfarwestspillspdf )

o CFW supplies roughly 40 of the water used by farmers in SSWD delivered in both Sutter and Placer Counties If Centennial is built in many water years CFW will have only runoff from Wolf Creek drainage and no runoff from the Bear River Serious shortfall of water in CFW will harm Placer County farmers

DRAFT DRAFT DRAFT DRAFT DRAFT American 8iver Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page lo8

o Farmers who have w~Hspumps wiHneeclto return to groundwater for their crops This will increase their costs increasemiddot environmental impacts and overtax the groundwater supply CFW was built in the 1960s because of American River Groundwater Subbasin overdraft as a result of CFW construction the Subbasin overdraft condition stabilized and recovered in the Northwest area of the Sub basin

o Retum to groundwater basin overdraft will threaten the groundwater supply of western Placer County private landowners who are dependent on wells and the cities ofLiricoln middot and Roseville who use groundwater to complement their surface water supplies for peaking as well as emergency supplies

o middot Agricultural overdraft of the northwestern part of the Sub basin will negatively impact recharge to the urban groundwater dema1Jd in southwestern Placer and eastern Sacramento Counties which is served by Cal Water Cal Water is the largest investorshyowned water utility west of tlie Mississippi River

2 Beardver canal impacts The high water levels ofCenteru1ial Reservoir arewithin dozens of feet below the Bear River Canal for most of the 7 milesmiddot The reservoir will supersaturate the substrate on which the canal is built Several sections of themiddot c~nal are already prone tomiddotmass wasting and landslide Two near catastrophic canal failures have occurred within the past thirtymiddot yeitrs neither of which occurred in the areas previously identified as prone to failure Placer County Water middot Agency depends on the Bear River Canal for delivery of 100000 acre-feetmiddotofurban and agricultural water supply Thorough investigation of thes~ potentially catastrophic impacts is needed

Public Health middot

1 Placer County has noted in comments that homes in tlJ_e inundation zone have septic tanks and leach lines that will have to be remediated Investigation will be needed for any other types of underground tanks or waste source at properties within the take line

2 Remediation of identified former garbage dumps and infotmal dumps For example the early 20th ~entury dump for Colfax was located on Milk Ranch Road below the Bear River Canal and is within the take line of Centennial Reservoir These old dumps are locationswhere people often dig illegally to discover antiques old bottles and other century old discarded items There is no record of dump contents nor were there any restrictions preventing dumping of toxic materials F of example in that era arsenic and lead arsenate were common pesticides and paint contained high levels of lead

Traffic Circulation and Safety

1 Stagi11g areas a11d com~truction noise inconvenience road maintenance and traffic hazards seem to be concentrated on the Placer County side at Peaceful Valley Road with access from I-80 via WeiIDar Cross Rd and Plac~r Hills Road or Placer Hills Roa~ thro1Jgh Meadow Vista ( drivers chqice) Road weight limits are in place w~ich mayn Hmit truck size and increase frequency of y~hicle trips or require heavy truc~s to travel throu$h Meadow Vista _downtown

2 A new Dog Bar bridge will transform rural Placer County residential traffic patterns in the Dog Bar Road Weimar Cross Road area and Placer Hills Road areas into a commuter corridor

DRAFT DRAFT DRAFT DRAFT DRAFT American River Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 3 of 8

becoming the commute route of choice between GV NC aild I-80 to AuburnRosevilleSacramento Grass ValleyNevada City Alta Sierra Lake of the Pines and Dark Horse traffic will likely use the new access to I-80 as time saving with additional safety of not having a steep and winding descent and ascent in and out of the Bear River canyon The new commuter route would bypass businesses lining Hwy 49 with negative economic impact to Placer County

3 Providing a new commuter transportation corridor is a growth inducing issuemiddoton the Nevada County side while increasing negative impacts oh Placer County side

4 A new commuter corridor will increase noise inconvertience and pollution and add safety concerns to Placer County residents At the proposed Dog Bar RoadPlacer Hills Road intersection commuters will pass schools inmiddot either direction in order to reach l-80 Placer Hills Road and Weimar Cross Roads aremiddot already a popular bicycle route used in numerous bicycle local and statewide races a commuter route is a hazardous path for cyclists

5 Reduction of traffic flow conditions bfmaking Milk Ranch Rd and Plum Tree Road dead end roads Evacuation alternatives to local residents will be eliminated creating culde-sac communities adding commute time to many of the residentsmiddot on those roads

Environmental Habitat Impacts

1 Loss of 2200 acres -of mixed conifer and oak wooqlands This ecosystem is uniquely rich because on the Placer County side the Bear liver Canal stands as a moat above the river at an elevation

_ of approximately 1850 feet The lands between the river and the canal are proWbited from development and is a de facto roadless natural preserve area There are few homes actually at riv~r elevation on the Nevada County side of the river due to steep canyon sides and limite_d acces~ The result is a band ofwildl~nclt~at is protected by these features Its richness is evidenced by presence of megafauna in particular mountain lion bobcat ringtai cat and bear

2 Loss of 7 miles of trout fishery and loss of miles of side creeks which also support rainbow trout fisheries

3 Habitat destruction of riparian zone home to Foothill Yellow-legged Frog which has been-listed by the State of California asan endangered speciesfrr a one year evaluation period

4 Habitat loss for ringtail cat bear bobcat mountain lion fox -3 Loss of migration corridor both upstreamdownstream andnorthsouthspeciesmigrations 4 Western Placer creeks which are habitat for salmon and endangered Steelhead will be affected by

the reduced flows in the lower Bear arid Feather River and all way down the Sacramento River through the Delta Western Placer creeks like Auburn Ravine Doty Ravine~ and Coon Creek have 3 runs of salmon with winter and spring runs including threatened salmon species

5 Placer County has not completed its conservation and recreation plan for this mid-elevation portion of the county Western Placer Countys plan is extensive and coI11plete and resulted in

middot the mitigation areas and investment in the Coon CreekHidden FatlsHargova Ranch park areas middotand lands held with conservation easements by Placer Land Trust tJntilthe Placer County planning process is completed a assessment and valuation cannot be done accurately This will mean lost opportunities for Placer Coui1ty s present and future residents

6 Lost opportunities for economic development All of the following areas could be developed for river access and increased recreational uses Most of the land on both sides of the river is in

DRAFT DRAFT DRAFT DRAFT DRAFT American ]Jiver Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 4 of~

public ownership primarily u1 NID ownership NIP has demonstrated an operations poli9y that discourages recreatio11al access at these pot~ntially Specifically

o Ben Taylor Road out of Colfax to the old Taylor Crossing has notp~en developed This was originally a Nisenan trade trail then-the main stagecoach crossing forthe Nevada CityColfax stagecoach road If tliis crossing were re-established itwould connect much used bicycle routes in both counties and provide access to trails on both sides of the river

o Dog Bar Road The Dog ~ar Bridge crossing provides access to trails both upstream and downstream This is a local favorite tubing and swimming hole area with well known jumping rocks Until the 1980s the cobble area on the Nevada County side on an NIP parcel was used for parking but the access road was blocked by NID loday the limited parking along Dog Bar Road is a public safety issue

o Peaceful Valley Road accesses a beautiful reach of the river most of which is owned by NID Accesstothisriver reach has been limited by private property owners

o Combie Road This road used to connect with Rutherford Road on the Nevada County side and was used publicly until the mid1900sas acrossing The river and qmicroarry gravel operations blocked access to the river Todays operation by Teichart continues to block these prior public access roads

7 The importance of future migration corridors and need for species refugia has not been fully assessed Sierra Streams Institute is presently in the process of updatin$ the Bear River

middot Watershed Inventory but this research projectand watershed plan will riot be completed for monthsyearsto come Particularly in themiddotera of climate change it isimportant to understand how species and entire biomes will be migrating up elevation It is afs6 important to understand northsouth ecosystem migration patterns that will result from climate change Until these patterns aremiddotunderstoOd an appropriate and legitimate evaluation and mitigation plan cannot be accomplished middot

Recreation

l Reduction ofrecreation andJourism ii) Placer County e~pecially in the City of Colfax due to elimination of the Bear River Campground Ihis is Placer Countys only campground It would berepktced bya campground 011the Nevada County side perched ona ridge off of Magnolia

middot Road well above reservoir levels This isreplacing high1quality recreation riverine camping sites

with low quality ridgetop camping sites which would be adjacent to the Higgins Comer Nevada County business area again on the Nevada County side

2 A network of trails aroundthe campg~ound has been developed and maintaipedhythe Meadow Vis~a Trails Associ~tion Many of the trails will be inundated A network of trails has been developed 011-the Nevada County side of tJie Bear River Campground used mostly by the residents and visitors to the private parcels on that side of the river this trail extends from Bear River Campground toDog BarAn informalnetworkoftrails exists bel0w DogBar on each side of the river through Peaceful Valley

3 Loss ofriver rafting reach All 7 miles of the threatened river are suitape foqafting kayaking and casual inner tube floating depending on the water levels bull This has high potential for

DRAFT DRAFT DRAFT DRAFT DRAFT American River Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 5 of8

increased recreational use as currently public access is not developed even though suitable access is owned by public entities

5 Demand for this river recreation is increasing and supply of good sites is small Whereas there are already a number of high quality reservoir recreation sites like Rollins Lake Valley Clementine Lake of the Pines Combie and even Folsom Centennial due to its major drawdown and level fluctuation with steep sidewalls requiring a 5 mph boating speed limit will be a low quality reservoir recreation sitebull

6 Gold panning has become increasingly popular as a family activity and this reach of river is considered some of the best gravel and cobble beds for panning with numerous points of access

Colfax hosts a store primarily dedicated to mining supplies Miners prefer the Bear River and rarely mine either Mineralmiddot bar or Yankee Jims on the American River Weimar has in past years also hosted a mining supplies store

7 Three areas on the Placer County side have high potential for increased river recreation and access in-the future Ben Taylor Rd Peaceful Valley Road and Combie Road Dam construction will eliminate these potential recreation areas

8 Due to extreme reservoir fluctuations reduction in recreation potential This ismiddothighlighted in NIDs application for recreation funds to the California Water Commission under Proposition I funding NID stated in the application that Centennial Reservoir would be drawn down before Rollins Reservoir in order to enhance the high water levelsin Rollins for motorized boating

(motorized boating in Centennial Reservoir is limited to 5 mph due to steep narrow canyon sides and erosion potential)

9 Lack of access to the proposed reservoir from Placer County side Primary restriction is the Bear River canal which runs the entire length of the reservoir on the Placer side Existing roads

accessing the river such as Milk Ranch Ben Taylor Plum Tree Peaceful Valley Road and Dog Bar maybe closed for safety reasons For example Peaceful Valley Milk Ranch and Plum Tree Roads become steep-sided and narrow below the Bear RiverCanal and do not allow tum-around or parking space muchless space for picnic tables and the like Additionally the aesthetics of

these dead end roads woulcl not attract visitors and much more likely would be attractive

Property Rights Real E~tate I Economic Losses

1 Loss of up to 30 homes and over I 00 undeveloped properties through eminent domain and purchase by NID Many of these homes and parcels are located in Placer County resulting in a

loss of tax revenues 2 Property owners in the affected area are reporting that the real estate market for them is now

utterly broken The uncertainty of the current situation has led to depressed housing values Landowners fear that when they are forced to sell to NID through eminent domain that the fair

market value for their properties will reflect this depressed value and not be fair 3 Property owners are reporting that the uncertainty is affecting their choices on maintaining their

homes Several have reported they are deferring maintenance like painting and roofing while

others are reporting abandoning plans for additions to their homes adding studios or other structures to their properties Deferring maintenance in tum devalues their homes in the appraisal process compounding their fears of not getting fair market value

DRAFT DRAFT DRAFT DRAFT DRAFT American River Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 3 of 8

becoming the commute route of choice between GV NC aild I-80 to AuburnRosevilleSacramento Grass ValleyNevada City Alta Sierra Lake of the Pines and Dark Horse traffic will likely use the new access to I-80 as time saving with additional safety of not having a steep and winding descent and ascent in and out of the Bear River canyon The new commuter route would bypass businesses lining Hwy 49 with negative economic impact to Placer County

3 Providing a new commuter transportation corridor is a growth inducing issuemiddoton the Nevada County side while increasing negative impacts oh Placer County side

4 A new commuter corridor will increase noise inconvertience and pollution and add safety concerns to Placer County residents At the proposed Dog Bar RoadPlacer Hills Road intersection commuters will pass schools inmiddot either direction in order to reach l-80 Placer Hills Road and Weimar Cross Roads aremiddot already a popular bicycle route used in numerous bicycle local and statewide races a commuter route is a hazardous path for cyclists

5 Reduction of traffic flow conditions bfmaking Milk Ranch Rd and Plum Tree Road dead end roads Evacuation alternatives to local residents will be eliminated creating culde-sac communities adding commute time to many of the residentsmiddot on those roads

Environmental Habitat Impacts

1 Loss of 2200 acres -of mixed conifer and oak wooqlands This ecosystem is uniquely rich because on the Placer County side the Bear liver Canal stands as a moat above the river at an elevation

_ of approximately 1850 feet The lands between the river and the canal are proWbited from development and is a de facto roadless natural preserve area There are few homes actually at riv~r elevation on the Nevada County side of the river due to steep canyon sides and limite_d acces~ The result is a band ofwildl~nclt~at is protected by these features Its richness is evidenced by presence of megafauna in particular mountain lion bobcat ringtai cat and bear

2 Loss of 7 miles of trout fishery and loss of miles of side creeks which also support rainbow trout fisheries

3 Habitat destruction of riparian zone home to Foothill Yellow-legged Frog which has been-listed by the State of California asan endangered speciesfrr a one year evaluation period

4 Habitat loss for ringtail cat bear bobcat mountain lion fox -3 Loss of migration corridor both upstreamdownstream andnorthsouthspeciesmigrations 4 Western Placer creeks which are habitat for salmon and endangered Steelhead will be affected by

the reduced flows in the lower Bear arid Feather River and all way down the Sacramento River through the Delta Western Placer creeks like Auburn Ravine Doty Ravine~ and Coon Creek have 3 runs of salmon with winter and spring runs including threatened salmon species

5 Placer County has not completed its conservation and recreation plan for this mid-elevation portion of the county Western Placer Countys plan is extensive and coI11plete and resulted in

middot the mitigation areas and investment in the Coon CreekHidden FatlsHargova Ranch park areas middotand lands held with conservation easements by Placer Land Trust tJntilthe Placer County planning process is completed a assessment and valuation cannot be done accurately This will mean lost opportunities for Placer Coui1ty s present and future residents

6 Lost opportunities for economic development All of the following areas could be developed for river access and increased recreational uses Most of the land on both sides of the river is in

DRAFT DRAFT DRAFT DRAFT DRAFT American ]Jiver Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 4 of~

public ownership primarily u1 NID ownership NIP has demonstrated an operations poli9y that discourages recreatio11al access at these pot~ntially Specifically

o Ben Taylor Road out of Colfax to the old Taylor Crossing has notp~en developed This was originally a Nisenan trade trail then-the main stagecoach crossing forthe Nevada CityColfax stagecoach road If tliis crossing were re-established itwould connect much used bicycle routes in both counties and provide access to trails on both sides of the river

o Dog Bar Road The Dog ~ar Bridge crossing provides access to trails both upstream and downstream This is a local favorite tubing and swimming hole area with well known jumping rocks Until the 1980s the cobble area on the Nevada County side on an NIP parcel was used for parking but the access road was blocked by NID loday the limited parking along Dog Bar Road is a public safety issue

o Peaceful Valley Road accesses a beautiful reach of the river most of which is owned by NID Accesstothisriver reach has been limited by private property owners

o Combie Road This road used to connect with Rutherford Road on the Nevada County side and was used publicly until the mid1900sas acrossing The river and qmicroarry gravel operations blocked access to the river Todays operation by Teichart continues to block these prior public access roads

7 The importance of future migration corridors and need for species refugia has not been fully assessed Sierra Streams Institute is presently in the process of updatin$ the Bear River

middot Watershed Inventory but this research projectand watershed plan will riot be completed for monthsyearsto come Particularly in themiddotera of climate change it isimportant to understand how species and entire biomes will be migrating up elevation It is afs6 important to understand northsouth ecosystem migration patterns that will result from climate change Until these patterns aremiddotunderstoOd an appropriate and legitimate evaluation and mitigation plan cannot be accomplished middot

Recreation

l Reduction ofrecreation andJourism ii) Placer County e~pecially in the City of Colfax due to elimination of the Bear River Campground Ihis is Placer Countys only campground It would berepktced bya campground 011the Nevada County side perched ona ridge off of Magnolia

middot Road well above reservoir levels This isreplacing high1quality recreation riverine camping sites

with low quality ridgetop camping sites which would be adjacent to the Higgins Comer Nevada County business area again on the Nevada County side

2 A network of trails aroundthe campg~ound has been developed and maintaipedhythe Meadow Vis~a Trails Associ~tion Many of the trails will be inundated A network of trails has been developed 011-the Nevada County side of tJie Bear River Campground used mostly by the residents and visitors to the private parcels on that side of the river this trail extends from Bear River Campground toDog BarAn informalnetworkoftrails exists bel0w DogBar on each side of the river through Peaceful Valley

3 Loss ofriver rafting reach All 7 miles of the threatened river are suitape foqafting kayaking and casual inner tube floating depending on the water levels bull This has high potential for

DRAFT DRAFT DRAFT DRAFT DRAFT American River Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 5 of8

increased recreational use as currently public access is not developed even though suitable access is owned by public entities

5 Demand for this river recreation is increasing and supply of good sites is small Whereas there are already a number of high quality reservoir recreation sites like Rollins Lake Valley Clementine Lake of the Pines Combie and even Folsom Centennial due to its major drawdown and level fluctuation with steep sidewalls requiring a 5 mph boating speed limit will be a low quality reservoir recreation sitebull

6 Gold panning has become increasingly popular as a family activity and this reach of river is considered some of the best gravel and cobble beds for panning with numerous points of access

Colfax hosts a store primarily dedicated to mining supplies Miners prefer the Bear River and rarely mine either Mineralmiddot bar or Yankee Jims on the American River Weimar has in past years also hosted a mining supplies store

7 Three areas on the Placer County side have high potential for increased river recreation and access in-the future Ben Taylor Rd Peaceful Valley Road and Combie Road Dam construction will eliminate these potential recreation areas

8 Due to extreme reservoir fluctuations reduction in recreation potential This ismiddothighlighted in NIDs application for recreation funds to the California Water Commission under Proposition I funding NID stated in the application that Centennial Reservoir would be drawn down before Rollins Reservoir in order to enhance the high water levelsin Rollins for motorized boating

(motorized boating in Centennial Reservoir is limited to 5 mph due to steep narrow canyon sides and erosion potential)

9 Lack of access to the proposed reservoir from Placer County side Primary restriction is the Bear River canal which runs the entire length of the reservoir on the Placer side Existing roads

accessing the river such as Milk Ranch Ben Taylor Plum Tree Peaceful Valley Road and Dog Bar maybe closed for safety reasons For example Peaceful Valley Milk Ranch and Plum Tree Roads become steep-sided and narrow below the Bear RiverCanal and do not allow tum-around or parking space muchless space for picnic tables and the like Additionally the aesthetics of

these dead end roads woulcl not attract visitors and much more likely would be attractive

Property Rights Real E~tate I Economic Losses

1 Loss of up to 30 homes and over I 00 undeveloped properties through eminent domain and purchase by NID Many of these homes and parcels are located in Placer County resulting in a

loss of tax revenues 2 Property owners in the affected area are reporting that the real estate market for them is now

utterly broken The uncertainty of the current situation has led to depressed housing values Landowners fear that when they are forced to sell to NID through eminent domain that the fair

market value for their properties will reflect this depressed value and not be fair 3 Property owners are reporting that the uncertainty is affecting their choices on maintaining their

homes Several have reported they are deferring maintenance like painting and roofing while

others are reporting abandoning plans for additions to their homes adding studios or other structures to their properties Deferring maintenance in tum devalues their homes in the appraisal process compounding their fears of not getting fair market value

DRAFT DRAFT DRAFT DRAFT DRAFT American ]Jiver Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 4 of~

public ownership primarily u1 NID ownership NIP has demonstrated an operations poli9y that discourages recreatio11al access at these pot~ntially Specifically

o Ben Taylor Road out of Colfax to the old Taylor Crossing has notp~en developed This was originally a Nisenan trade trail then-the main stagecoach crossing forthe Nevada CityColfax stagecoach road If tliis crossing were re-established itwould connect much used bicycle routes in both counties and provide access to trails on both sides of the river

o Dog Bar Road The Dog ~ar Bridge crossing provides access to trails both upstream and downstream This is a local favorite tubing and swimming hole area with well known jumping rocks Until the 1980s the cobble area on the Nevada County side on an NIP parcel was used for parking but the access road was blocked by NID loday the limited parking along Dog Bar Road is a public safety issue

o Peaceful Valley Road accesses a beautiful reach of the river most of which is owned by NID Accesstothisriver reach has been limited by private property owners

o Combie Road This road used to connect with Rutherford Road on the Nevada County side and was used publicly until the mid1900sas acrossing The river and qmicroarry gravel operations blocked access to the river Todays operation by Teichart continues to block these prior public access roads

7 The importance of future migration corridors and need for species refugia has not been fully assessed Sierra Streams Institute is presently in the process of updatin$ the Bear River

middot Watershed Inventory but this research projectand watershed plan will riot be completed for monthsyearsto come Particularly in themiddotera of climate change it isimportant to understand how species and entire biomes will be migrating up elevation It is afs6 important to understand northsouth ecosystem migration patterns that will result from climate change Until these patterns aremiddotunderstoOd an appropriate and legitimate evaluation and mitigation plan cannot be accomplished middot

Recreation

l Reduction ofrecreation andJourism ii) Placer County e~pecially in the City of Colfax due to elimination of the Bear River Campground Ihis is Placer Countys only campground It would berepktced bya campground 011the Nevada County side perched ona ridge off of Magnolia

middot Road well above reservoir levels This isreplacing high1quality recreation riverine camping sites

with low quality ridgetop camping sites which would be adjacent to the Higgins Comer Nevada County business area again on the Nevada County side

2 A network of trails aroundthe campg~ound has been developed and maintaipedhythe Meadow Vis~a Trails Associ~tion Many of the trails will be inundated A network of trails has been developed 011-the Nevada County side of tJie Bear River Campground used mostly by the residents and visitors to the private parcels on that side of the river this trail extends from Bear River Campground toDog BarAn informalnetworkoftrails exists bel0w DogBar on each side of the river through Peaceful Valley

3 Loss ofriver rafting reach All 7 miles of the threatened river are suitape foqafting kayaking and casual inner tube floating depending on the water levels bull This has high potential for

DRAFT DRAFT DRAFT DRAFT DRAFT American River Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 5 of8

increased recreational use as currently public access is not developed even though suitable access is owned by public entities

5 Demand for this river recreation is increasing and supply of good sites is small Whereas there are already a number of high quality reservoir recreation sites like Rollins Lake Valley Clementine Lake of the Pines Combie and even Folsom Centennial due to its major drawdown and level fluctuation with steep sidewalls requiring a 5 mph boating speed limit will be a low quality reservoir recreation sitebull

6 Gold panning has become increasingly popular as a family activity and this reach of river is considered some of the best gravel and cobble beds for panning with numerous points of access

Colfax hosts a store primarily dedicated to mining supplies Miners prefer the Bear River and rarely mine either Mineralmiddot bar or Yankee Jims on the American River Weimar has in past years also hosted a mining supplies store

7 Three areas on the Placer County side have high potential for increased river recreation and access in-the future Ben Taylor Rd Peaceful Valley Road and Combie Road Dam construction will eliminate these potential recreation areas

8 Due to extreme reservoir fluctuations reduction in recreation potential This ismiddothighlighted in NIDs application for recreation funds to the California Water Commission under Proposition I funding NID stated in the application that Centennial Reservoir would be drawn down before Rollins Reservoir in order to enhance the high water levelsin Rollins for motorized boating

(motorized boating in Centennial Reservoir is limited to 5 mph due to steep narrow canyon sides and erosion potential)

9 Lack of access to the proposed reservoir from Placer County side Primary restriction is the Bear River canal which runs the entire length of the reservoir on the Placer side Existing roads

accessing the river such as Milk Ranch Ben Taylor Plum Tree Peaceful Valley Road and Dog Bar maybe closed for safety reasons For example Peaceful Valley Milk Ranch and Plum Tree Roads become steep-sided and narrow below the Bear RiverCanal and do not allow tum-around or parking space muchless space for picnic tables and the like Additionally the aesthetics of

these dead end roads woulcl not attract visitors and much more likely would be attractive

Property Rights Real E~tate I Economic Losses

1 Loss of up to 30 homes and over I 00 undeveloped properties through eminent domain and purchase by NID Many of these homes and parcels are located in Placer County resulting in a

loss of tax revenues 2 Property owners in the affected area are reporting that the real estate market for them is now

utterly broken The uncertainty of the current situation has led to depressed housing values Landowners fear that when they are forced to sell to NID through eminent domain that the fair

market value for their properties will reflect this depressed value and not be fair 3 Property owners are reporting that the uncertainty is affecting their choices on maintaining their

homes Several have reported they are deferring maintenance like painting and roofing while

others are reporting abandoning plans for additions to their homes adding studios or other structures to their properties Deferring maintenance in tum devalues their homes in the appraisal process compounding their fears of not getting fair market value

DRAFT DRAFT DRAFT DRAFT DRAFT American River Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 5 of8

increased recreational use as currently public access is not developed even though suitable access is owned by public entities

5 Demand for this river recreation is increasing and supply of good sites is small Whereas there are already a number of high quality reservoir recreation sites like Rollins Lake Valley Clementine Lake of the Pines Combie and even Folsom Centennial due to its major drawdown and level fluctuation with steep sidewalls requiring a 5 mph boating speed limit will be a low quality reservoir recreation sitebull

6 Gold panning has become increasingly popular as a family activity and this reach of river is considered some of the best gravel and cobble beds for panning with numerous points of access

Colfax hosts a store primarily dedicated to mining supplies Miners prefer the Bear River and rarely mine either Mineralmiddot bar or Yankee Jims on the American River Weimar has in past years also hosted a mining supplies store

7 Three areas on the Placer County side have high potential for increased river recreation and access in-the future Ben Taylor Rd Peaceful Valley Road and Combie Road Dam construction will eliminate these potential recreation areas

8 Due to extreme reservoir fluctuations reduction in recreation potential This ismiddothighlighted in NIDs application for recreation funds to the California Water Commission under Proposition I funding NID stated in the application that Centennial Reservoir would be drawn down before Rollins Reservoir in order to enhance the high water levelsin Rollins for motorized boating

(motorized boating in Centennial Reservoir is limited to 5 mph due to steep narrow canyon sides and erosion potential)

9 Lack of access to the proposed reservoir from Placer County side Primary restriction is the Bear River canal which runs the entire length of the reservoir on the Placer side Existing roads

accessing the river such as Milk Ranch Ben Taylor Plum Tree Peaceful Valley Road and Dog Bar maybe closed for safety reasons For example Peaceful Valley Milk Ranch and Plum Tree Roads become steep-sided and narrow below the Bear RiverCanal and do not allow tum-around or parking space muchless space for picnic tables and the like Additionally the aesthetics of

these dead end roads woulcl not attract visitors and much more likely would be attractive

Property Rights Real E~tate I Economic Losses

1 Loss of up to 30 homes and over I 00 undeveloped properties through eminent domain and purchase by NID Many of these homes and parcels are located in Placer County resulting in a

loss of tax revenues 2 Property owners in the affected area are reporting that the real estate market for them is now

utterly broken The uncertainty of the current situation has led to depressed housing values Landowners fear that when they are forced to sell to NID through eminent domain that the fair

market value for their properties will reflect this depressed value and not be fair 3 Property owners are reporting that the uncertainty is affecting their choices on maintaining their

homes Several have reported they are deferring maintenance like painting and roofing while

others are reporting abandoning plans for additions to their homes adding studios or other structures to their properties Deferring maintenance in tum devalues their homes in the appraisal process compounding their fears of not getting fair market value

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American River Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 6 of 8

4 Property owners are reporting loss of a personal sense of well-being confusion regarding future

life plans and depression This state of limbo began in 2014 with the surprise announcement of

Centennial Dam ( at that time it was called Parker Dam from the original 1926 proposal) Some

property owners have begun documenting their physical and emotional challenges and have even

begun a conversation about a class action suit for damages and personal suffering

5 Loss of real estate values due to poor aesthetics of reservoir The June 2017 ACW A study coshy

funded by NID states that reservoir levels above NIDs target carry-over of 40000 acre-feet

would be available for integrated system-wide use That means that drawdown of 75000 acreshy

feet of water would translate would be down to an estimated 1750 feet elevation from the high

water mark of 1850 feet elevation This is a reservoir bathtub ring of approximately 100 feet of

exposed eroded canyon-side with stumps and other debris If the reservoir is operated in this

way property values in the area wil1 go down Rather than lakefront property the situation will

be more similar to living next to a seasonally fluctuating water resource strip mine with nuisance

locations for il1egal camping with fire dangers and other illicit uses These conditions are also

more difficult to patrol for Placer Sheriff and other public safety organizations 6 Economic negative impact reduction in recreation and tourist industries All proposed

campground and boating access mitigations are located on the Nevada County side with easy

access to the Higgins Corner business area The Colfax Weimar and Meadow Vista businesses

that currently benefit from riverine recreation and the Bear River Campground will not be located conveniently for Centennial Reservoir visitors

Cultural Historic Losses

1 Historic Holmes Limestone Kiln located on the river between will be inundated This is a

fantastic 19th century designed bee hive kiln for processing lime It is currently overgrown with brush and vines in the understory of oak woodlands but is in remarkably good condition This

site is clearly a candidate for a historic preservation designation but to date no one has made this

effort

2 Historic Prichard marble quarry and wagon road will be inundated httpsierrageologyorgimagespritchard-marble

3 Historic area of Rising Sun gold mine will be inundated Preceding the marble and limestone

quarries was this gold mine dominating this hill all the way to the river

4 Historic Ben Taylor Crossing of the stage coach route between Colfax and Nevada CityGrass

Valley inundated

5 Loss of over 150 Native American sites of the Nisenan tribal groups including 8 village sites and

burialburning ceremonial grounds Centennial Dam is opposed by two recognized Nisenan

tribes United Auburn Indian Community (UAIC) and Shingle Springs Rancheria Centennial is

opposed by three unrecognized Nisenan tribes Nevada City Rancheria Colfax-Todds Valley

Consolidated Tribe and the Meadow Vista Enos Nisenan

6 Loss of currently used Nisenan cultural sites These are called Traditional Cultural Properties

which are areas currently used for cultural ceremonies (like river baptism for infants) and cultural

practices like medicine gathering and sourcing of stones for making traditional implements and

ceremonial stones used for cooking and other purposes The Colfax-Todds Valley Consolidated

Tribe (httpwwwcolfaxrancheriacom) and the Clipper Gap families descended from Lizzie

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American River Watershed Institute (ARWI) Opinion Paper on Potential Centennial Project Impact to Placer County page 7 of8

Enos are the most directly affected (http bearriverusnisenanphp ) Several of the members and staff of the United Auburn Indian Community (UAIC wwwauburnranc) live throughout the area including within the proposed reservoir take line

Potential Impact to Placer County RatePayers

Nevada Irrigation District delivers more than half of its water to customers in Placer County The high growth areas within NID are also located in Placer County names the North Auburn area and the City of Lincoln In Centennial Dam NID is proposing the most expensive public works project ever in our region The fundamental questions are How much will the project cost And how will NID pay for this project

The most recent estimates range from NID internal estimate of $350 million to the estimate in ARWIs white paper of $550 million The differences between the two are primarily the omission in the NID estimates of mitigation costs and the hydropower component (which NID states is part of a separate project at Rollins even though it uses Centennial Reservoir as the afterbay) These costs need to be adjusted for inflation yearly until 2022 which is our estimate of construction NID now states that bonds would be issued so the financing costs and interest need to be added to the project This brings the total cost of the project to a range of between $750 million and $15 billion depending on the final costs included in the bond issue

NID has over the past three years named a number of potential sources of revenue but out-ofshydistrict water sales and modest hydroelectric revenues with a very modest $12 million in State funding are the only possibilities That leaves the ratepayers on the hook for project costs The ARWI analysis shows that this could mean a doubling of current water rates This is a drain of resources from our community to the bondholders outside of our community and an undeserved level of financial burden on the individual ratepayer Details of this financial analysis can be found at this link

httpwwwsavebearrivercomuploads47 3847384675opcpcr 21 feb interim finalpdf

Potential Impacts to Placer County Farmers

Farmers in Placer County will be negatively affected in three ways 1 Camp Far West reservoir below the proposed Centennial Reservoir will be dewatered in most

years directly reducing surface water available to the farmers of South Sutter Water District (SSWD) SSWD has filed a protest to the NID application for water rights to the State Water Resources Control Board Negotiations to resolve the dispute after one year are at a complete stalemate over the question of which entity will have senior rights

2 Centennial Dam will greatly diminish surface water supplies to Placer and Sutter farmers who constitute approximately 40 and 60 respectively of SSWDs customers This will be an economic hardship and will threaten the viability of commercial farming

3 Reduced deliveries from Camp Far West (CFW) will force farmers who have groundwater access back to pumping groundwater for their crops CFW was constructed to alleviate groundwater

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overdraft of the American River Groundwater Sub basin Placer County farmers that depend on groundwater will see increased costs due to pumping and will see the subbasin return to an overdraft condition threatening the sustainability of the groundwater resource

4 Increased rates will impact Placer County farmers using NID surface water supplies due to rate increases caused by the cost of Centennial Dam

For additional information

httpwwwsavebearrivercomuploads 47 38 4 73 8467 5 otiswollan-parkerdam campfarwestspil lspdf