Audubon California

October 24, 2003

Ms. Celeste Cantu, Executive Director
State Water Resources Control Board

Mr. Michael Harris, Deputy Director
Department of Fish and Game

Dr. Jeanine Jones, Principal Engineer
Department of Water Resources

Mr. Tom Kirk, Executive Director
Salton Sea Authority

Re: Criteria and Goals for Restoration of the Salton Sea

We are writing on behalf of Audubon's many California members, scientific colleagues and wildlife supporters to provide criteria and goals for wildlife protection and habitat restoration at the Salton Sea. This memo is intended to help guide restoration planning and provide a framework for evaluating restoration plans as they relate to wildlife, which the State has recognized as an internationally significant resource at the Salton Sea. The objectives below address the needs of wildlife, particularly birds, since that is Audubon's area of expertise. We assume that experts in other areas will address air and water quality, local economic development and other important restoration issues separately.

We hope that the objectives detailed below will help inform and shape restoration planning and we look forward to working together to ensure that the final restoration plan protects and restores wildlife and its habitat in the Salton Sea ecosystem.

A list of the individuals who advised Audubon and participated in the development of this memo is provided as Appendix A.

I. GOALS FOR WILDLIFE AND HABITAT RESTORATION

Restoration of the Salton Sea must achieve the maximum feasible protection and restoration of wildlife habitat, including aquatic and shoreline habitat, as well as habitat on the surrounding agricultural lands. Newly enacted Fish and Game Code section 2931 clarifies that the intent of the Legislature is "restoration of the Salton Sea ecosystem and the permanent protection of the wildlife dependent on that ecosystem." The preferred alternative for restoration must achieve, among other things, the maximum feasible "restoration of long-term stable aquatic and shoreline habitat for the historic levels and diversity of fish and wildlife that depend on the Salton Sea." Id.

In order to achieve these goals, restoration must:

Preserve and enhance all existing ecosystem and habitat types in and around the Salton Sea, including agricultural lands that provide important habitat.
Ensure no net loss of the diversity and abundance of wildlife species.
Provide adequate monitoring before, during and after restoration planning to ensure a scientifically sound basis for restoration.
Establish a permanent scientific research station at the Sea and adequate funding for ongoing research related to wildlife and habitat.

We describe each of these in more detail below.

II. PRESERVATION OF ALL EXISTING HABITAT TYPES

The Salton Sea ecosystem contains numerous habitat types, each of which is necessary to maintain the historic levels and diversity of wildlife that depend on the ecosystem. Some of the habitat types and species most dependent on them are described below.

A. AGRICULTURAL LANDS

Agricultural lands in Imperial Valley provide habitat for numerous species of concern and species that are highly dependent on those lands for their survival. Restoration plans should include measures for conserving important agricultural land habitat and helping to facilitate that conservation through federal and state grant programs. Restoration of the Salton Sea ecosystem must ensure that fallowing and efficiency measures are consistent with habitat preservation on the agricultural lands.

1. Permanently or Frequently Flooded Lands

This habitat type includes alfalfa and other crops that are frequently flooded. It is characterized by shallow, standing water (optimal depth is 6 inches), moist soils and open habitats or crops that are cut back periodically.

Species that depend on this type of habitat include Cattle Egret,White-faced Ibis, Gull-billed and Black Terns, Long-billed Curlew and Whimbrel.

2. Dry Crops

This habitat type is characterized by recently plowed, grazed or burned fields. Species that forage on agricultural lands but prefer dry lands include Ferruginous Hawk, Burrowing Owl, many species of sparrow, curlew, Mountain Plover, Loggerhead Shrike and Sandhill Crane (which also needs shallow impoundments).

Taller, shrublike crops such as cotton and grapes do not generally provide good habitat for wildlife.

3. Canals, Drains, Seeps and Riparian Zones

The vegetation along canals - particularly native species such as arrowweed and willows - provide crucial habitat for migrant and wintering songbirds (some of the highest numbers of migrants recorded anywhere in California, according to PRBO Conservation Science). Unlined canals, drains and seeps provide the principal nesting habitat for Burrowing Owl (canal/levee sides only), and Black Rail. These species rely on seeps that form on the outside of levees throughout the Imperial Valley. Burrowing Owls rely on the banks of unlined earthen canals for nesting sites. Canal lining must be implemented in such a way as to minimize the impacts to these species or must be mitigated. Mitigation must be monitored to ensure it is providing adequate alternative habitat.

B. SHORELINE, SHALLOW WATER AND MUDFLATS

Fish and Game Code section 2931(c)(1) requires the maximum feasible restoration of long-term, stable shoreline at the Salton Sea. Restoration should ensure the long-term protection of the entire Salton Sea shoreline and, especially, the southern shoreline. Protection must include mudflats (vegetative and non-vegetative), shallow water habitats to 15 inches deep, freshwater marshes, brackish water, all three river deltas, and areas that alternate inundation and drying. The southern shoreline of the Sea is the most critical to protect because of its gentler slope, which provides much greater shallow water habitat than the steeper sloped northern shoreline. Any restoration plan should include protection and enhancement of the entire southern shoreline, including the southeastern shoreline.

A substantial portion - perhaps more than half - of the Sea's shoreline should be protected from industry, urbanization and heavy recreation by the designation of wilderness, parkland or wildlife refuge.

Species that depend on these habitat types include migrant and wintering shorebirds, waders, dabbling ducks, raptors, both Brown and American White Pelicans, avocets and stilts, migrant and wintering songbirds such as Wilson's Warblers,and breeding Western Snowy Plovers (which nest in salt panes at the edge of the Sea).

C. DEEP WATER AND ISLANDS

Species that rely on open, deep-water habitat include Eared, Western and Clark's grebes, pelicans, Ruddy Duck, Phalaropes and Black Tern. Preservation of deep-water habitat requires an adequate, reliable, and relatively stable water supply that is guaranteed in perpetuity. In addition, restoration must maintain acceptable levels of salinity, nutrients, contaminants such as selenium, and water depth. At a minimum, the Sea must be maintained to a depth of 30 feet or more to ensure sufficient deep-water habitat.

Islands provide critical habitat for colonial nesting birds that require a predator-free environment and unobstructed access to water for thermoregulation. As Sea level declines, existing islands will no longer be surrounded by water, exposing some of the nesting species to predators. Already, the northern end of the Sea has lost its only island, near Johnson Street and east of the Whitewater River mouth, which is now connected to the mainland and thus has been abandoned by terns and skimmers.

Restoration must maintain channels, fences or other means of protecting the isolation of these islands. An immediate restoration project could include channeling around that island to provide adjacent water and protection from predators. Restoration planning and feasibility studies should also consider the benefits of constructing additional islands for habitat. Species that rely on islands for predator-free nesting habitat include cormorants, terns, skimmers, and the species dependent on deep-water habitat listed above.

D. FRESH-WATER MARSHES

Fresh water marshes around the perimeter of the sea provide important habitat for a variety of bird species including the federally endangered Yuma Clapper Rail, Least Bittern, and other marsh birds. This habitat is especially important at the south end of the sea in the state and federal wildlife areas. Many of the waterbirds using this habitat, including ducks and shorebirds, move frequently between these freshwater marshes and the saltier Salton Sea.

Restoration must ensure that the hydrology of these systems is not negatively altered and that adequate fresh water supplies continue to feed these systems.

III. DIVERSITY AND ABUNDANCE OF SPECIES

Section 2931 requires protection of the historic levels and diversity of fish and wildlife at the Salton Sea. To achieve the maximum feasible diversity and abundance of species, restoration must focus on the number of species as well as individual species' historic population levels. Since 1999 is the most recent year for which population data exists for most of these species, we recommend that 1999 be used as the baseline for "historic level."

Restoration should ensure protection of all threatened, endangered, sensitive, California Species of Special Concern and Fully-Protected Species. Restoration should also focus on species that are not currently listed under state or federal law, but would likely need to be without adequate protection of their Salton Sea habitat, and on those species that depend in large numbers on the Sea. For instance, 80 percent of California's White Pelicans depend on the Sea and adjacent shoreline, 70 percent of California's Western Burrowing Owls depend on the agricultural landscape of the Imperial Valley Salton Sea habitat, and over one third of the world's population of Mountain Plovers rely on the Salton Sea ecosystem.

IV. MONITORING AND RESEARCH

Current monitoring of the Salton Sea and surrounding habitats is not adequate to provide a sound scientific basis for long-term wildlife restoration plans. Funding should be provided immediately to monitor and research the following:

Relationship between water quality, invertebrates, fish and bird populations
Wildlife population estimates for target species
Quantity, characteristics and specific locations of important bird habitats in the lower Coachella Valley (within the Salton Sink) and the Imperial Valley
Effects of the existing geothermal plant and related infrastructure (power lines, effluent, etc.) on the Sea and on birds
Specific location and attributes of habitat provided by drains and canals
Effects of type and placement of different agricultural practices on birds
Diet of birds at the Salton Sea and the effects of pollutants in this diet
Effects of increased urbanization around the Salton Sea, including the effect of increased tourism and recreation on the Sea and shoreline.
Movements of birds among different habitats within and around the Salton Sea, including the Imperial Valley.

We strongly recommend the use of staff and contractors with specific expertise in the Salton Sea ecosystem and wildlife dependent on that ecosystem for both monitoring and research.

The Center on Inland Waters at San Diego State University is already researching and monitoring the connections between water quality, invertebrates, fish and bird populations. We recommend funding the continuation and expansion of this work as a critical underpinning of restoration planning and adaptive management for wildlife dependent on the Sea.

PRBO Conservation Science (PRBO) is uniquely qualified and experienced at monitoring and modeling bird population densities and habitat needs. In 1999, PRBO oversaw the first year-long, comprehensive bird study at the Salton Sea, documenting abundance, distribution and phenology of birds at and around the Sea. We recommend using PRBO for monitoring the bird species at the Salton Sea.

The Natural History Museum of Los Angeles has extensive experience monitoring colonial nesting waterbirds (cormorants, herons, egrets, ibis, gulls, terns and skimmers) and shorebirds (Snowy Plovers, avocets and stilts), and should be contracted with to continue and expand that work as part of the restoration planning process.

To the extent that the Torres-Martinez Tribe's restoration work on the north shore is included in habitat restoration plans, it should be monitored and adapted to maintain and enhance existing habitat. Any restoration planning and actual restoration should be done in cooperation with the Tribe and should support the Tribe's efforts to restore habitat.

V. ONGOING SCIENTIFIC RESEARCH

Restoration of an ecosystem as complex as the Salton Sea will require ongoing scientific research, in addition to monitoring, to be able to develop effective adaptive management tools, as required by legislation, and meet restoration goals. Establishment of a permanent research station, with adequate facilities, funding, a boat, etc. would facilitate research and the exchange of data among scientists from different institutions. Ideally, such research stations would be established at both the north end (managed by the State) and the south end (managed by the Federal Government) of the Sea.

The institution(s) responsible for research and monitoring must ensure that all areas of scientific research and monitoring related to the Salton Sea ecosystem are integrated, peer-reviewed and made publicly available as quickly as possible to ensure successful restoration planning and enable effective adaptive management.

We would be happy to provide more background on any of these issues, and look forward to working with your agencies to ensure that restoration meets the objectives outlined above.
Please feel free to contact either one of us with questions or comments.

Sincerely,

Julia Levin, State Policy Director Dan Cooper, Director of Bird Conservation