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Santa Ana Delhi Diversion Project - 2 - February 25, 2016 <br />easily observed when on -site, a freshwater emergent wetland exists in the <br />section of the Santa Ana -Delhi Channel (channel) downstream of the Mesa <br />Street Bridge and the proposed Project site. In this location, fresh water pools <br />form above the tidal influence that wildlife utilizes. California Department of Fish <br />and Wildlife species of special concern and Federal Endangered Species Act <br />listed species have been reported utilizing the freshwater marsh. The United <br />States Geologic Survey biological survey team and others have periodically <br />identified western pond turtle (Actinemys rnarmorata palllda), a California <br />Department of Fish and Wildlife species of special concern, in this section of the <br />channel. The California least tern (Sternula antillarum brown), federally listed as <br />endangered, feeds in the freshwater sections of the channel as reported in the <br />1993 EIR and by local wildlife experts. As such, the Project proponents should <br />determine avoidance, minimization or mitigation resulting from Project impacts to <br />the listed and other freshwater marsh species established in the areas <br />downstream of the Project site. <br />In addition, United States Fish and Wildlife Service (USFWS) staff expressed <br />concerns over the reduction of channel flows into Upper Newport Bay that would <br />result from the implementation of this Project, and possible impacts to the salt- <br />water marsh located downstream of the channel confluence with the Bay. <br />Recently, USFWS staff provided Regional Board staff with a documene that <br />describes the benefits of adequate nutrients to a healthy salt -water marsh. The <br />Project proponents should respond to USFWS' concern prior to implementing the <br />Project, and consider Project options to avoid potential adverse impacts to the <br />downstream salt marsh. <br />The implementation of the Project could result in increased erosion in the <br />earthen downstream sections of the channel. Implementation of the Project <br />would remove sediment from dry weather flows along the earthen section of the <br />channel from Mesa Street to the Bay. The lack of sediment deposition could <br />encourage greater scouring during wet weather flows, but the MND does not <br />discuss this possibility. Board staff recommends conducting a hydraulic study of <br />the channel examining sediment transport prior to determining whether to <br />construct the Project. <br />The MND states that during wet weather, water may be allowed to pool several <br />feet deep behind the diversion structure before it is released downstream. The <br />Project proponents should consider the effects of these wet weather releases to <br />the downstream sections of channel and the habitat. In addition, the Project <br />proponents should evaluate whether allowing routine smaller releases versus <br />Personal communication with USFWS staff Chris Medak. <br />z Zedler, 1993, "Canopy Architecture of Natural and Planted Cord grass Marshes: Selecting Habitat Evaluation <br />Criteria ". <br />20B -24 <br />