Estimated Cost for Appendix K Compliance Biological Surveys Marie Campbell President, Sapphos Environmental, Inc. December 15, 2011

Sapphos Environmental, Inc. Recognized leader in biological resources management Conducted hundreds of surveys for species listed as rare, threatened or endangered pursuant to Federal and State Endangered Species Acts Expertise encompasses all applicable taxonomic groups: wetland and riparian plants, fish, birds, amphibians, and reptiles One of California’s largest private sector team of biologists Experience and pivotal work in the six major California water regions: –Sacramento Valley –North Coast –San Joaquin Valley –North Coast –Central Coast –North Coast

San Marino Environmental Associates Recognized expert in aquatic biology Pivotal work with of California special status aquatic species including unarmored threespine stickleback, Santa Ana sucker, red- legged frog, and southwestern pond turtle Clients include: –US Fish and Wildlife Services –US Army Corps of Engineers –California Department of Fish and Game –Los Angeles County Department of Public Works Extensive Federal and State permitting experience: –Section 7 consultations/Section 10(1) Incidental Take Permits –Section404 permits –Section 1600 Streambed Alteration Agreements –Section 2081 Incidental Take Permits

Composite Historic Range of Decision Species

Applicability of Appendix K Surveys Over 4,000 lakes and reservoirs in California Of the 78 most popular vacation lakes –2 in excess of 100,000 acres –14 between 10,000 and 100,000 –55 between 1,000 and 10,000 acres –7 between 5 and 100 acres Over 20,000 registered ponds Affects all waters of the state, such as: Majority of California lakes, reservoirs, ponds, golf course ponds, and backyard ponds (i.e. Koi Ponds) –Stocked by CDFG or private property owners –Suitable habitat for Appendix E Decision Species California anglers spent over $2 billion on recreational fresh water sport fishing trips and related equipment in 2008

Implications of Appendix K Surveys Estimated Cost –Habitat Assessment ≈ $1500 per 10 linear miles of shoreline –Directed Surveys $3 to $70K per acre Cost is not proportional to size of water body Average Cost for 4 Case Studies was $133,000 Applied to 24,000 potential impoundments, cost could exceed $3 billion –5 Year Recurring Cost Subject to revocation with changed condition No certainty

Methods Evaluated four California lakes –Captures range of potentially regulated water bodies Size ranged from 2 to 579 acres Geographically Diverse –Irvine Lake, Orange County –Dixon Lake, San Diego County –Knickerbocker Lake,Placer County –Cakebread Lake, Napa County Characterization –Size of lake (Area in Acres/ Perimeter in Linear Feet) –Depth –Private or public –Associated amenities –Habitat Assessment –Relation to Historic Range for Decision Species

Knickerbocker Lake,Placer County, approximately 8 acres Cakebread Lake, Napa County, approximately 2 acres Irvine Lake, Orange County, approximately 579 acres Dixon Lake, San Diego, approximately 63 acres

Irvine Lake Fish: Trout, largemouth bass, catfish, crappie, bluegill, redear sunfish, sturgeon, wiper, and carp. Uses: Launch ramps, a café, picnic and barbeque areas, private boat and recreational vehicle storage, and a kids lagoon.

Dixon Lake Fish: The lake is often stocked with catfish and trout. Uses: Camping areas, barbeques, boating, hiking, and picnics.

Knickerbocker Lake Uses: Private leisure activities: (fishing, camping, and swimming)

Cakebread Lake Uses: Private leisure activities, such as fishing, camping, and swimming.

Findings Cost Estimates factor in potentially present Decision Species All case studies had potentially suitable habitat Cost Estimates were based on USFWS and CDFG survey protocols The size of the water body is not a predictor of regulatory costs. California Natural Diversity Database indicated potential presence of 3 to 13 Decision Species

Conclusion Proposed regulations potentially affect 24,000 California bodies of water Appendix E of the EIR/EIS highlights approximately 80 Decision Species Potentially suitable habitat for at least on Decision Species present at most water bodies Estimated average case study survey cost of ≈ $133,345 Potential 5 year recurring cost: 24,000 x $133,345 = $3,200,280,000