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 The Stanislaus River Restoration Plan Information Site

The California Rivers Restoration Fund, California Trout, Friends of the River, the South Yuba River Citizens League, and the Tuolumne River Preservation Trust (collectively Conservation Groups) hereby support the Petition of the National Marine Fisheries Service For Modifying Project Structures and Operations, dated May 2, 2003 (NOAA Petition). Pursuant to Articles 10, 37, and 58 and other applicable authorities, the Commission should undertake a formal consultation under the Endangered Species Act (ESA) section 7(a), in a public proceeding open to the participation of the Districts and other parties, to determine whether the Article 37 minimum flow schedule and other project operations harm Central Valley steelhead in the Tuolumne River, and if so, evaluate and adopt reasonable and prudent measures to prevent such harm.

1. In 1964 the Commission granted Modesto Irrigation District and Turlock Irrigation District (collectively, the Districts) a major license under Section 4(e) of the Federal Power Act (FPA) to construct, operate, and maintain the project on the Tuolumne River. 31 FPC 510 (1964). The project provides irrigation and municipal water supply, hydroelectric power, flood control, recreation, and fish and wildlife conservation. Id. Article 37 established a minimum flow schedule (MFS) "for fish purposes" for the first 20 years of project operation. Article 39 required the Districts to study during that period whether the original MFS "assur[ed] the continuation and maintenance of the fishery of the Tuolumne River in the most economical and feasible manner."

2. In1995 the Districts and other parties entered into the New Don Pedro Proceeding P-2299-024 Settlement Agreement (1995 Agreement). This agreement proposes a "strategy for recovery of Tuolumne River Chinook salmon" below La Grange Dam. Id., 8.

On February 5, 1996, the Districts filed a conforming application to amend the project license to establish a new MFS based on the results of the Article 39 study. Pursuant to ESA section 7(a), the U.S. Fish and Wildlife Service (FWS) published a Biological Opinion regarding the impact of the license amendment on Delta smelt and Sacramento splittail. The Commission determined that the new MFS would benefit the Chinook salmon fishery. 76 FERC 61,117 (1996), 1996 FERC LEXIS 1617, **21. It approved the license amendment, and Articles 37 and 58 were revised accordingly.

3. In 1998, NOAA listed the Central Valley Steelhead Evolutionary Significant Unit (steelhead) as threatened under the ESA. 63 Fed. Reg. 13,347 (March 19, 1998). Substantial evidence exists, as discussed below, that the steelhead fishery in the Tuolumne River is self-sustaining and is harmed by the Article 37 MFS. Accordingly, NOAA has filed its Petition requesting that the Commission initiate formal consultation and reopen the license to modify the Article 37 MFS in order to protect both steelhead and Chinook salmon in the Tuolumne River. The Districts have agreed to be the non-federal representatives in such consultation. See letter from Walter P. Ward and Robert M. Nees to George H. Taylor (March 31, 2003).

4. The Conservation Groups acknowledge and are grateful for the considerable efforts by the Districts to implement the 1995 Agreement and to monitor the impacts of the new MFS through the Tuolumne River Technical Advisory Committee (TRTAC). We file this brief in the hope and expectation that the Districts will undertake now to study and protect the steelhead fishery with the same diligence.

5. The California Rivers Restoration Fund (CRRF) is a non-profit corporation dedicated to finding viable solutions for the management, protection, and restoration of habitat for steelhead, salmon, and other game fish in California. CRRF's directors have been actively involved in efforts to restore salmonid habitat in the lower Tuolumne River, and in some instances have collaborated with the Districts on their restoration projects. Many of its members are sport anglers that frequently fish the San Joaquin River basin. Its membership also consists of property and business owners located along the lower Tuolumne. It has offices in Soulsbyville and El Dorado, California.

6. California Trout (CalTrout) is a conservation organization with over 5,300 members. CalTrout's mission is to protect and restore wild trout, native steelhead and the waters they inhabit throughout California. Its work includes participating in the Commission's dam relicensing proceedings, protecting the public trust, reforming grazing practices on public lands, expanding the wild trout program, and recovering decimated steelhead populations statewide. Its headquarters is in San Francisco, California.

7. Friends of the River (FOR) is California's statewide river conservation organization, with more than 5,000 members. FOR educates, organizes, and advocates to protect and restore California rivers streams, and watersheds. It is nationally recognized as an authority on the adverse impacts of dams on rivers and ecosystems. FOR actively is involved in the relicensing of hydroelectric projects on the Kern, San Joaquin, Stanislaus, Mokelumne, American, Feather, Sacramento, and Klamath Rivers, and serves on the steering committee of the California Hydropower Reform Coalition. Its headquarters is in Sacramento, California.

8. The South Yuba River Citizens League (SYRCL) is a grassroots, community-based organization. It has over 4,500 supporters and 500 active volunteers who are dedicated to protecting, restoring, and enjoying the Sierra Nevada's Yuba River watershed and rivers throughout California. SYRCL strives to find working solutions to environmental problems through education, organization, collaboration, legislation and litigation. SYRCL collaborates with and serves as a model for other river-related conservation groups in California. It is a member of the California Hydropower Reform Coalition. It has been an outspoken advocate for the Commission's initiating consultation for listed species found in and around the Yuba River. It brings the knowledge and experience gained from its involvement in licensing matters on the Yuba River to this proceeding. Its headquarters is in Nevada City, California.

9. The Tuolumne River Preservation Trust (Trust) is a non-profit organization that works to promote the stewardship of the Tuolumne River and its tributaries to ensure a healthy watershed. The Trust was a party signatory to the 1995 Agreement and has actively participated thereafter in TRTAC. Its headquarters is in San Francisco, California.

10. California Sportfishing Protection Alliance [XX].

11. Conservation Groups seek to protect the native steelhead fishery that may be affected adversely by the Article 37 MFS and other aspects of project operations. Individual members of the Conservation Groups use and enjoy the Tuolumne River for recreation and for its biological and aesthetic values. The project operation affects the suitability of these waters for those uses. If the NOAA Petition and our request for relief below are granted, we are prepared to collaborate with the Districts, regulatory agencies, and other stakeholders to undertake the necessary study of the impact of project operations on the steelhead fishery.

12. Under several articles, the Commission has the necessary authority to grant the NOAA Petition, evaluate project impacts on the steelhead fishery, and amend the license as appropriate on the basis of that consultation. Articles 2 and 3 generally reserve authority to reopen the license and modify any approved specifications. Article 5 provides that project operations "shall at all times be controlled by such reasonable rules and regulations as the Commission may prescribe for the protection of life, health, and property, and in the interest of the fullest practicable conservation and utilization of such waters for power purposes and for other beneficial public uses, including recreational purposes…."

13. Article 10 specifically provides that: "The Licensee shall, for the conservation, and development of fish and wildlife resources, construct, maintain, and operate, or arrange for the construction, maintenance and operation of such facilities and comply with such reasonable modifications of the project structures and operation as may be ordered by the Commission upon its own motion or upon the recommendation of the Secretary of the Interior or the fish and wildlife agency or agencies of any State in which the project or a part thereof is located, after notice and opportunity for hearing and upon findings based on substantial evidence that such facilities and modifications are necessary and desirable, reasonably consistent with the primary purpose of the project, and consistent with the provisions of the Act."

14. Most importantly, Article 58 requires the Districts to undertake a continuing program to monitor project impacts on the Chinook salmon fishery and report on study results by April 1, 2005. The Commission will then "determine whether to require further monitoring studies and changes in project structures and operations to protect fishery resources in the Tuolumne River, after notice and opportunity for hearing."

15. The stated purpose of the 1995 Agreement is to employ instream flow and non-flow measures to (1) increase naturally occurring Chinook salmon populations, (2) protect any remaining genetic distinction, and (3) increase the salmon habitat in the Tuolumne River. 1995 Agreement at 2. The strategy did not include any measures specifically negotiated or designed to protect the steelhead fishery.

16. The Commission published a Final Environmental Impact Statement: Reservoir Release Requirements for Fish at the New Don Pedro Project, California (July 1996) (FEIS). It analyzed the impacts of the proposed action and alternatives on the Chinook salmon fishery. No analysis was performed to determine the impacts on resident rainbow trout and anadromous steelhead, based on the belief that there were "no significant populations of rainbow/steelhead in the lower Tuolumne River." Id. at 3-65.

17. The original license was amended in 1996 in conformity with the 1995 Agreement. 71 FERC 61,117. Articles 37 and 58 were amended to incorporate the MFS and non-flow measures provided in that agreement. Id. at 61,609. The 1996 Order was directed exclusively to protect, mitigate, and enhance the Chinook salmon fishery. Id.

18. In its final determination to list the Central Valley steelhead ESU as threatened, NOAA noted that observations resulting from monitoring efforts for Chinook salmon documented steelhead juveniles and/or adults in the lower San Joaquin River, the Stanislaus River, the Tuolumne River, and the Merced River. 63 Fed. Reg. 13,353 (emphasis added). These steelhead appeared to represent natural production because hatchery releases in past years had been made only into the Mokelumne River. Id. In addition to the data on which NOAA based its final determination, Conservation Groups have gathered further information confirming the presence of steelhead in Tuolumne River below La Grange Dam.

19. In a June 15, 2001 communication to the TID, Dennis McEwan, California Department of Fish and Game (CDFG) Team Leader, stated that the evidence for the existence of steelhead in the Tuolumne River is "overwhelming." See email from Dennis McEwan to Tim Ford (June 15, 2001) (Attachment 1). He stated: "[g]iven the fact that there is successful natural production, smolt emigration, and steelhead-sized adults, I find it difficult to conclude that there isn't evidence of a steelhead run in the Tuolumne." Id.

20. On March 29, 2002, Steve Walser, CRRF Executive Director, met with Michael Aceituno, NOAA, and other representatives from CDFG, United States Fish and Wildlife Service (FWS), CalFed, Northern California Council Federation of Fly Fishers (NCCFFF), and the Districts. See Declaration of Steve Walser (Attachment 2), at 5. During this meeting, Mr. Walser presented photographs and videotape footage of steelhead he and Robert T. Smith, CRRF Board Member and professional fishing guide, caught in the lower Tuolumne River. Id. Walser and Smith caught most of the steelhead between January and May; the period during which adult ocean-maturing steelhead migrate into the Central Valley tributaries to spawn. Id.

21. The CDFG has additional evidence that juvenile and adult steelhead occur in the lower Tuolumne River. William Loudermilk, CDFG Regional Manager, reported to the Commission that CDFG staff did "have substantive field data collections to substantiate the presence of both adult and out-migrating juvenile steelhead with[in] the Tuolumne River downstream of the Project No. 2299 facilities." See letter from William E. Loudermilk to Erick Gaedeke (December 15, 2001).

22. On January 21, 2001, Kenneth Kundargi, CDFG staff biologist, sent a memorandum to CDFG staff, NOAA, FWS, and others. See Memo from Ken Kundargi to CDFG staff et al. (Attachment 3). In the memorandum he reported his capture of an adult male steelhead, 28 inches in length and approximately 10 pounds in weight, and a steelhead smolt in the lower Tuolumne River. Id.

23. On May 20, 2002, Mr. Walser and Mr. Smith took Eric Theiss, NOAA, on a fishing tour of the lower Tuolumne River between the Old La Grange Bridge and Basso Bridge. Attachment 2 at 6. The group caught five adult steelhead, which ranged in size from 17 inches to 5 pounds. Id. The fish caught exhibited steelhead characteristics including (1) males with hooked jaws, (2) deep red operculum, (3) two with a bright silver color, (4) lateral stripe, and (5) the males were milting. Id. Mr. Theiss agreed that the fish caught probably were steelhead. Id.

24. Juvenile steelhead have different habitat requirements than Chinook salmon. Steelhead adults typically spawn between December and June (63 Fed. Reg. 13,347.), while Chinook salmon spawn mostly between October and January (FEIS at 3-48). Juvenile steelhead rear in freshwater from 1 to 4 years, prior to migrating to the ocean as smolts, while juvenile Chinook salmon outmigrate on the spring flows following spawning. Id. Steelhead need coldwater habitat throughout the summer months for rearing.

25. Summer water temperatures in the lower Tuolumne below La Grange Dam were not suitable for steelhead in 2001 and 2002. See Average Daily Temperature Chart for Rivermile (RM) 50.5, Old La Grange Bridge (Attachment 4). According to CDFG data gathered between June 2, 2001 and June 10, 2001, water temperatures at the Old La Grange Bridge (RM 50.5) ranged between 14º C and 15º C (57.2º F and 59.0º F). Id. The mean flow from La Grange dam (RM 52.2) for this period was 55.8 cfs. See Mean Flow Data for Tuolumne River Below La Grange Dam (Attachment 5). Between June 15, 2001 and July 10, 2001, the mean flow from La Grange Dam was 51.8 cfs, and temperatures of 15º C to 16º C (59.0º F to 60.8º F) were recorded at that location. See Attachment 4, Attachment 5. The CDFG data indicated that in June and July 2001 the water temperatures increased rapidly in a downstream direction. See Attachment 4. Downstream from Old La Grange Bridge, between the J59 Bridge (RM 49.8) and the Basso Bridge (RM 47.5), maximum water temperatures ranged between approximately 19.0º C and 21.5º C (66.2ºF and 70.7º F) between June 15, 2001 and July 10, 2001. Id. Near the downstream boundary of the 11-mile steelhead reach, between Turlock State Park (RM 43.2) and the 7-Eleven Aggregate Company (RM 38), maximum water temperatures ranged between 27º C and 28º C (81º F and 82º F).

26. Project operations contributed to these unsuitable temperatures. According to NOAA, "[r]educing flows at a time of elevated air temperatures in late spring and early summer exacerbates unsuitable habitat conditions for CV steelhead by increasing the water temperatures to physiologically stressful levels, thereby increasing CV steelhead mortality." NOAA Petition at 9.

27. According to Dr. Carl Mesick, juvenile and adult steelhead require water temperatures at or below 65º F in the lower Tuolumne River. See Declaration of Dr. Carl Mesick (Attachment 7) at 2. Dr. Mesick evaluated how different flow releases from La Grange Dam affect the amount of habitat in the lower Tuolumne River. Id. Based on his analysis he concluded that a release of 100 cfs from La Grange Dam during the summer provides suitable water temperatures in an average of 30% of the 11-mile reach used by steelhead in the lower Tuolumne River. Id.

28. On June 10, 2001, Mr. Walser observed approximately 20 dead steelhead in the lower Tuolumne River below the Old La Grange Bridge. Attachment 2 at 3. He did not collect specimens of the dead fish, but he did take photographs. He observed many people removing dead fish from the river and placing them in coolers. Id. at 4. He also was able to take a water temperature reading below the Basso Bridge, which read 22.2º C (72.0º F). Id. He immediately attempted to notify CDFG staff stationed at the field office in La Grange, but the office was closed. Id.

29. According to Mr. Walser, Sacramento pike minnow and Sacramento sucker in the lower Tuolumne River also died near the Old La Grange Bridge in June 2001. See Attachment 2 at 4. The death of Sacramento pike minnow and Sacramento sucker, which have a greater tolerance for high temperatures than salmonids, further indicates that the temperature condition in the lower Tuolumne was harmful to steelhead during that period. Dead Chinook salmon and American shad were observed further downstream during subsequent surveys. Id. The combined effect of stress from high temperatures and other stressors, such as low dissolved oxygen concentrations, likely resulted in the fish kill. See Attachment 7 at 3.

30. In summer 2002, Mr. Walser and Dr. Mesick placed onset thermographs at 3 locations in the lower Tuolumne River. See Attachment 6. Data from these thermographs were collected between June 6, 2002 and November 5, 2002. Id. From June 6, 2002 to October 7, 2002, the mean flow at La Grange was 83 cfs. Id. Water temperatures reached their maximum during the first week of July when flows were approximately 87 cfs. Id. A flow release of 87 cfs provides suitable habitat for approximately 3.45 to 5.5 miles of steelhead habitat in the Tuolumne River. Id. When water temperatures are below 18.3º C, adult steelhead have been documented throughout an 11-mile stretch of the lower Tuolumne River below La Grange Dam. See Attachment 2 at 3. Thus, flow releases in summer 2002 were adequate to support steelhead in approximately 40% of their potential habitat.

31. In a letter dated June 11, 2002, NOAA requested the Commission initiate formal consultation under Section 7(a)(2) of the ESA for federally licensed operations of NDPP. See letter from Rodney R. McInnis to Magalie Roman Salas (June 11, 2002) FERRIS 20020628-0308. The June 11, 2002 letter was written in response to information that TID planned to reduce flows from 150 cfs to 75 cfs, the minimum summer flows required by its license. Id. NOAA informed the Commission that the flow regime for summer 2002 (roughly 75 cfs) likely would be inadequate to sustain oversummer rearing, given what NOAA knew about the temperature requirements of juvenile steelhead. Id. at 3; see also Attachment 1 at 3. NOAA also referred to reports from private individuals and complaints from recreational fishing groups that described fish kills resulting from previous flow reductions. Id. Furthermore, NOAA informed the Commission that adverse impacts - stranding, predation, elevated water temperatures, loss of habitat - might result from further flow reductions. Id.

32. On November 19, 2002, NOAA wrote a second letter to the Commission requesting formal consultation for the impacts of NDPP operations on steelhead. See letter from Rodney R. McInnis to Magalie Roman Salas (November 19, 2002) FERRIS 20030220-0293. NOAA stated that "Central Valley anadromous fish management and research has been primarily focused on Chinook salmon and this has lead to inadequate efforts to monitor and restore steelhead." Id. It also stated that "[a]ctivities to protect steelhead in the Tuolumne River need to address the substantial loss of spawning and rearing habitat due to blockages by dams, such as, providing suitable water temperatures year-round in reaches comprising steelhead rearing habitat." Id. According to NOAA, the minimum releases prescribed by Article 37 of license, as amended in 1996, "allows summer water temperatures in steelhead habitat to rise above lethal thresholds." Id.

33. As shown by this evidence, Article 37 MFS and other project operations probably cause harm to the steelhead fishery below La Grange Dam. More generally, hydropower projects may adversely affect such a fishery through a number of direct and indirect mechanisms, which include: (1) habitat degradation due to altered stream flow, i.e. the loss of quantity and/or quality of wetted surface area, water depth, water velocity, substrate, or cover; (2) change in water quality, i.e. changes in dissolved oxygen, salinity, water temperature, or toxicity; (3) direct mortality; and (4) prevention of fish passage. See Oak Ridge National Laboratory, Summary Report of Potential Cumulative Effects of Hydropower Projects in the Bay Delta, California 7 (October 1995) (prepared for Commission, Division of Project Compliance and Administration, Office of Hydropower Licensing). An analysis of the potential cumulative effects of hydropower projects in the Bay Delta concluded that NDPP was one of nine licensed projects where cumulative impacts of project operations on fish were much more likely. Id. at 8.

34. The ESA plainly requires that the Commission initiate consultation in response to the NOAA Petition. Under Section 7(a)(1) of the ESA, "Federal agencies shall, in consultation with and with the assistance of the Secretary, utilize their authorities in furtherance of the purposes of this chapter by carrying out programs for the conservation of endangered species and threatened species listed pursuant to section 1533 of this title. 16 U.S.C. § 1536. Section 7(a)(2) provides, "[e]ach Federal agency shall, in consultation with and with the assistance of the Secretary, insure that any action authorized, funded, or carried out by such agency is not likely to jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of habitat of such species which is determined by the Secretary … to be critical …." Id. NOAA' rules broadly define a federal action to include "all activities or programs of any kind authorized, funded, or carried out, in whole or in part, by Federal agencies in the United States or upon the high seas." 50 C.F.R. § 402.02.

35. A federal agency must reinitiate consultation "if a new species is listed or critical habitat designated that may be affected by the identified action." 50 C.F.R. § 402.16(d). Here, the 1995-6 consultation that preceded the 1996 Order also preceded the 1998 listing of steelhead fishery in the lower Tuolumne. Evidence subsequent to that consultation demonstrates that the listed fish are present in the Tuolumne below La Grange Dam, and that the Article 37 MFS and other aspects of project operations may affect such fish.

36. Now that we have confirmed that listed steelhead are present below the project, ESA section 7(a)(2) requires formal consultation to determine the likelihood of impacts and evaluate reasonable and prudent alternatives.

"No formal consultation is required if the action agency finds, with the Services written concurrence, that the proposed action 'may affect, but is not likely to adversely affect' listed species or critical habitat….This finding can be made only if ALL of the reasonably expected effects of the proposed action will be beneficial, insignificant, or discountable. " FWS, ESA Section 7 Consultation Handbook (1998), p. 4-1 (emphasis in original).

37. Further, the Commission and the Districts alike have a duty under ESA section 9 to avoid taking steelhead as a result of project operations. 16 U.S.C. § 1538(a)(1). Under the ESA, "take" is defined broadly to mean "harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in such conduct." 16 U.S.C. § 1532(19). Further, the Commission must review its actions at the earliest possible time to determine whether any action it takes "may affect" listed species or their critical habitat. 50 C.F.R. § 402.14(a). Given NOAA's two letters and now its Petition, the Commission should promptly establish a proceeding for formal consultation to address the impacts of project operations on the steelhead fishery.

38. Plainly, such a proceeding should also address potential impacts on the Chinook fishery. Under Article 58, the Districts, in consultation with the CDFG and the FWS, are implementing a program to monitor Chinook salmon populations and habitat in the Tuolumne River. Article 58 requires that study results will be published in annual reports. Id. The final study results will be filed by April 1, 2005. Id. Based on these study results, the Commission will determine whether to require further monitoring studies and changes in project structures and operations to protect fishery resources in the Tuolumne River, after notice and opportunity for hearing. Id. Because any modification in the Article 37 MFS or other project operations to prevent harm to the steelhead fishery may affect the Chinook salmon fishery, formal consultation as requested in the NOAA Petition should be undertaken in conjunction with the preparation of the Article 58 report.

39. The Commission should issue public notice of the proceeding that is established for formal consultation and any related reopener that addresses the impacts of project operations on the steelhead fishery. It should permit intervention in this proceeding. Most importantly, it should encourage the Districts, NOAA, and other parties to participate in a collaborative manner to address project impacts on steelhead in connection with the Article 58 report that will be submitted not later than April 1, 2005. Such further procedures will allow interested the signatories of the 1995 Settlement and other interested parties to participate, consistent with the National Environmental Policy Act (NEPA), Administrative Procedures Act, and FPA Part I.

40. The National Environmental Protection Act (NEPA) requires public review prior to any decision that may result in a significant impact on environmental quality. 42 U.S.C. §§ 4321-4347. The Commission must:

(a) make diligent efforts to involve the public in preparing and implementing their NEPA procedures;

(b) provide public notice of NEPA-related hearings, public meetings, and the availability of environmental documents so as to inform those persons and agencies who may be interested or affected."

40. C.F.R. § 1506.6(a), (b); 18 C.F.R. § 380.9(a)(1).

41. Any action resulting from such formal consultation may have a significant impact on environmental quality. As the Commission found in the previous amendment proceeding, any modification in the Article 37 MFS "could significantly impact the human environment by reducing municipal and industrial water supplies," and require preparation of a Final Environmental Impact Statement. FEIS at xxv.

42. The Conservation Groups request service of any further pleading in this proceeding, on the following representatives:

Steve Walser
Chairman,
CALIFORNIA RIVER RESTORATION FUND
P.O. Box 236
Soulsbyville, CA 95372
(209) 532-7146
(209) 588-1306 (fax)

Dr. Carl Mesick
Senior Fishery Biologist/Vice Chairman
CALIFORNIA RIVER RESTORATION FUND
7981 Crystal Boulevard
El Dorado, CA 95623-4817
(530) 620-3631 (phone/fax)

Brian Stranko
Marketing and Communications Director
CALIFORNIA TROUT, INC.
870 Market Street
San Francisco, CA 94102
(415) 392-8887
(415) 392-8895 (fax)
stranko@caltrout.org

Kelly Catlett
Hydro Reform Advocate
FRIENDS OF THE RIVER
128 J Street, 2nd Floor
Sacramento, CA 95814-2207
(916) 442-3155, ext. 223
(916) 442-3398 (fax)
kelly@friendsoftheriver.org

Todd Hutchins
RiverLaw Director
SOUTH YUBA RIVER CITIZENS LEAGUE
216 Main Street
Nevada City, CA 95959
(530) 265-5961, ext. 203
todd@syrcl.org

Jenna Olsen
Executive Director
TUOLUMNE RIVER PRESERVATION TRUST
914 13th Street
Modesto, CA 95354
(209) 236-0330
(209) 236-0311
jenna@tuolumne.org

Julie Gantenbein
Richard Roos-Collins
NATURAL HERITAGE INSTITUTE
2140 Shattuck Avenue, 5th floor
Berkeley, CA 94704
(510) 644-2900
(510) 644-4428 (fax)
jgantenbein@n-h-i.org
rrcollins@n-h-i.org.

The Conservation Groups respectfully request that the Commission grant the NOAA Petition, reinitiate consultation in connection with the Article 37 MFS with respect to project impacts on steelhead, and establish a public proceeding for such formal consultation.
Dated: June 10, 2003

Respectfully submitted
Richard Roos-Collins
Julie Gantenbein
NATURAL HERITAGE INSTITUTE

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