Silverado Canyon Dams Bombed

Update March 23 USFS BOMBED the endangered birds and won't allow me
in to take photographs


Explosives truck -
Results of swimming hole demolition #1 -
Results of swimming hole demolition #2 -

Results of swimming hole demolition #1 -
Results of swimming hole demolition #2 -
Results of swimming hole demolition #3 -

1) We have confirmed that Forest Biologist Kirsten Winter is the lead on this project.
2) Explosives were ignited multiple times during wildlife breeding season in a section of Silverado Creek that is officially designated as Critical Habitat for the endangered Arroyo Toad, Kit Fox and Southwestern Willow Flycatcher.
3) No recent Arroyo Toad surveys were conducted in this wet year after years of inadequate drought conditions.  Surveys would normally be conducted in spring of wet years.
4) The USFS asked for an exemption from Section 7 of the Endangered Species Act Survey Protocol in order to conduct the explosive demolition project in designated Critical Habitat for the endangered Arroyo Toad but did not ask for exemption for the Southwestern willow flycatchers nesting there and the Kit Fox den.
5) Breeding California Newts, treefrogs, nesting birds and other wildlife were molested, disturbed or possibly killed by the explosives demolition in Silverado Creek.  According to their own Environmental Assessment, the USFS is not legally allowed to schedule the project at this time of year.
6) The USFS broke their promise after positive negotiations with the community.
7) The explosives impacted the water clarity and may have impacted the water quality.
8) The USFS was ineffective at communicating with the public about this project.
9) Our community is heartbroken, but determined to hold the USFS, Marines, USFWS and County accountable for their insensitive, disrespectful and destructive actions.
10) The USFS plans to use these same methods in Holy Jim Canyon, Trabuco Canyon and San Juan Canyon, but we are determined to prevent these destructive methods from happening in the Trabuco Ranger District of the Cleveland National Forest.

Please sign our petition, spread the word and voice your concern to Forest Supervisor William Metz, District Ranger Darrell Vance and local elected officials (congress, supervisor,etc).
Forest Supervisor William Metz via La Sean Brown -

I received notice that the Silverado Canyon, California some five dams built in the 1940's will be dynamited in the coming weeks. Blown up and back hoe's digging in this beautiful place. Removing dams will end waterfalls,  swimming holes and kill local species. Orange County hikers and naturalists beware!

I contacted my Senator, Audubon Society, the Parks Department and the Rangers who plan to
set the fuses yesterday.

A pair of Southwestern Willow Flycatchers live next to one of the swimming holes, and
yellow legged frogs are hatching in the shallow mud due to the unusual amounts of rain
we experienced. Both of these creatures are on the endangered species list.

The reasoning for dam removal seems to be they believe this will bring steel head up the dry creek. Trout were long ago planted in this area but they are not native.

If you are a hiker or enjoy Holy Jim, Silverado, the Cleveland National Park please contact the links below or give them a phone call ASAP

Appendix B: Response to Comments

Trabuco District Dam Removal 

The Forest Service has documented, analyzed, and responded to the public comments received during the scoping and comment periods for the Trabuco District Dam Removal Project. This appendix summarizes the comments that were received during the scoping and comment periods and provides the agency’s response to those comments. These responses comply with 40 CFR 1503.4, Response to Comments, of the National Environmental Policy Act (NEPA) regulations.

Comment Analysis and Response

Public comments submitted were documented, compiled, categorized, and analyzed in order to capture all viewpoints and concerns submitted during the official scoping and comment periods. Information from letters, emails, and other sources are all included in this response to comments. The response to comments helps the USDA Forest Service clarify, adjust, or incorporate additional technical information into the EA.
Comments were not tallied or listened to. The Forest Service is acting on directives from higher sources and doesn't care about public input

Specialists read all public responses and identified separate comments within them that relate to a particular concern, resource consideration, and/or requested management action. Specialists categorized each comment into a subject area that is specifically relevant to this project. After categorizing comments, responses were written to address the public input that was received. The interdisciplinary team provided any recommendations for improvement to the proposed action to the Trabuco District Ranger for review, consideration, and action. In general, the agency responds in the following five basic ways to substantive public comments, as prescribed in 40 CFR 1503.4:

1. Modifying alternatives.
2. Developing and analyzing alternatives not initially given consideration.
3. Supplementing, improving, or modifying the analysis documented in the EA.
4. Making factual corrections.
5. Explaining why the comments do not need further Forest Service response.

This response document is organized based on the categorization of comments into subject areas, as described above. Therefore, the organization of this appendix does not directly match the organization of the EA and is instead more closely tied to the concerns that the public shared during the scoping period with the proposed action. Comments that may have fit into several categories were addressed only once.

It is important to point out that the consideration of public comments is not a vote-counting process in which the project outcome is determined by the majority opinion. More importantly, it is the appropriateness, specificity, and factual accuracy of comment content that serves to provide the basis for modifications to planning documents and decisions. Further, because respondents are self-selected, they do not constitute a random or representative public sample. NEPA encourages all interested parties to submit comments as often as they wish. Every substantive comment and suggestion has value, whether expressed by one respondent or many. All input is read and evaluated, and the analysis team attempts to capture all relevant public concerns in the analysis process.

Per the legal notice, the 30 day period to comment on the Trabuco District Dam Removal Environmental Assessment began September 24, 2013, and ended October 24, 2013.  Eleven comments were received by email, two comments were received by USPO mail, and no comments received by telephone during this time period.  Several comments were received after the close of the comment period and are not part of the official record, although the Forest agreed to consider late comments.

1.      Cost and financial concerns:  

1.1  Commenters stated that the cost of removing the dams was too high and not a good use of funding.   
Waste of Money with no benefit. Who gains from the water course being changed? Who owns the water resource? Where do the riparian rights of owners go? Is the State taking the water?

Response to 1.1:  See alternatives comparison chart, Section 2.4 of Environmental Assessment, which displays the cost of the various alternatives. See also response to comment 4.8, which discusses the risks of no action.  Please note that the Forest is seeking funds that are specifically allocated for removal of fish barriers for this project; these funds, if received, may not be used for other types of projects.

1.2  Purpose and need does not justify the proposed action

Response to 1.2: See revised purpose and need section in Section 1.3 of Environmental Assessment which provides additional detail regarding the rationale for the project. 

1.3   How can cabin owners seek compensation if cabins are damaged by project work or subsequent effects.

Response to 1.3 - If cabin owners believe they can show that their property has been damaged due to a Forest Service action, they may file a claim for recovery of damages.

2.      Historic concerns:   

2.1  The rock dams have historic value and should be preserved.

Thousands of hikers, artists, writers and locals have enjoyed this area as it stands for the past seventy seven years. Why do you say natural beauty has no merit?

Response to 2.1- The Trabuco District Dams are a series of check dams placed intermittently within Trabuco Creek, Holy Jim Creek, San Juan Creek, and Silverado Creek on the Trabuco Ranger District of the CNF. The dams are made of rock and mortar. They were constructed by Orange County in the 1940s as part of a fish stocking project, in which the County constructed check dams for an approximately 10 year period. The original objectives of the program were to enhance local fishing potential, conserve water and wildlife, and provide water for fire protection. The program boomed during the 1950s and 1960s by creating popular fishing areas. The program began to wane during the 1970s, which led to the deterioration and subsequent removal of some of the dams. Of the approximately 108 original dams, 81 are still intact to the point where they need to be demolished to allow for fish passage.  These 81 dams are located along Trabuco Creek, Holy Jim Creek, Silverado Creek, and San Juan Creek. Due to the potential eligibility of the dams for nomination to the National Register due to their age (>50 years), association with local history, and the potential adverse effect of the proposed demolition, the dams were recommended for a  Determination of Eligibility (DOE) evaluation and associated SHPO consultation prior to any decision regarding the proposed demolition, in accord with Section 106 of the National Historic Preservation Act (NHPA) and the Regional Programmatic Agreement (RPA 2013).

An evaluation and draft DOE report for the three intact dams in Trabuco Creek was prepared by the Heritage Stewardship Group (HSG), a U.S. Forest Service Enterprise Business Unit specializing in historic preservation and cultural resource management. To develop the DOE, HSG’s Architectural Historian utilized data and documentation provided by the CNF Heritage Program, Trabuco Ranger District, Orange County Archives, Orange County Historical Society, Cal Fire, and Orange County Fire Authority in addition to using secondary literature. Project fieldwork was completed by Forest Heritage Program and Resources staff in March 2013. Fieldwork included photography and documentation of the physical aspects of all of the 108 known check dams and the surrounding landscape. The evaluation was completed by an architectural historian who meets the Secretary of the Interior’s Professional Qualifications Standards per 36 CFR 61. The draft report is in the process of being rewritten to include documentation (DPR Archaeological Site forms), evaluation and DOE for all of the 108 known dams that may potentially be included in the demolition project, rather than just the three primary intact dams in Trabuco Creek, based on verbal consultation with SHPO. The projected completion date for the final draft is January 2014. The original evaluation resulted in a preliminary determination that the three intact dams, although of some local interest and importance, do not meet any of the four National Register criteria for significant Historic Properties, according to the Architectural Historian that conducted the evaluation. SHPO verbally indicated that it could concur with that determination, and that the remainder of the dams would not be considered historic by association, as they are in very poor condition and are lacking in integrity, or have been removed completely. Once the draft evaluation has been provided for public comment it will be finalized and submitted to SHPO for concurrence, prior to any decision regarding the proposed demolition of the dams, in accord with Section 106 of the NHPA and the RPA.

3.      Scenic values concerns. 

3.1  Dams and associated “waterfalls” are scenic and should be preserved. Removal of the dams will impair the scenic integrity of the area.

Say goodbye to all the waterfalls that hikers enjoyed. Water will go underground

Response to 3.1–  Please see expanded discussion of Scenery Objectives, Section 3.3 of
EA. The CNF Land Management Plan (2006) specifies a Scenic Integrity Objective level of “High” for the entire project area, a classification that “provides for conditions where human activities are not visually evident.” In other words, man-made artifacts like dams are considered to detract from, rather than add to, the area’s scenic integrity.

3.2  Leaving rock materials in place after dam demolition will decrease scenic value of area; waste materials will be left in unsightly mounds
Response to 3.2.  Please see additional discussion, Section 3.3 of EA. Please note that all of the streams currently have roads, road crossings, rip-rap, gabions, retaining walls, remnants of failed dams, and other types of materials present in and adjacent to stream channels. Due to the dynamic nature of these streams, rock and concrete fragments resulting from dam demolition will be transported downstream and out of the project area over time, during rainfall events.

3.3  Defunct installations such as these dams detract from the forest experience and should be removed.
Response to 3.3 – Thank you for this comment, which supports the information presented in the Environmental Assessment.

3.4  Holy Jim Canyon is not a Wilderness so it should not be restored to a more natural condition.
Response to 3.4 -  Please note that the Forest Land Management Plan states that  Scenic Integrity Objectives for Trabuco/Holy Jim, San Juan, and Silverado are “high”; and Ortega Highway Corridor (San Juan) is a Scenic Byway.  A Scenic Integrity Objective of “High” is the equivalent of a landscape that appears unaltered.  See Scenic Integrity Objectives map in Forest Plan.   The landscape strategy (Land Management Plan Part 2, page 105) includes direction to “Restore landscapes to reduce visual effects of management activities and nonconforming features”.  Appendix E provides direction for Riparian Conservation Areas, and states that the Forest will allow “only those actions that maintain or improve long-term aquatic ecosystem health.”  Please see also the discussion of scenic values, Section 3.3 of EA.

4.      Hydrological concerns:  
4.1 Removal of dams will increase the extent of the floodplain in and downstream of project   area
Response to 4.1 –  The dams were not constructed for flood control. At a  6th field watershed HUC scale, they have not changed the duration, timing, or water inundation levels during past major flood events such as the 50-100 year floods of 1938 and 1969.  Therefore, the 100-year floodplain width that existed prior to dam construction is the same width that occurs today 40-70 years after the structures were initially constructed. Although the extent and function of the 100-year floodplains are not affected by this project, due to the interest expressed by several commenters, additional information about floodplain mapping is provided here. 

Floodplains are the relatively flat lowland that borders a river, usually dry but subject to flooding. Floodplain soils actually are former flood deposits  (USGS webpage, 2013).  

Existing FEMA flood mapping for San Juan, Silverado, and Trabuco Creeks covers areas just downstream of the Cleveland National Forest boundary (FEMA Map Service Center, 2013)   The FEMA mapping shows that the floodplains in these streams overlap with two soil types-  Riverwash, and Soboba cobbly loam.    The USDA Soil Conservation Service has mapped soils in this area (USDA Soil Conservation Service 1978) and describes these soil types as follows:

Riverwash –  Riverwash consists of areas of unconsolidated alluvium, generally stratified and varying widely in texture, recently deposited by intermittent streams, and subject to frequent changes through stream overflow.

Soboba  series  - The Soboba series consists of excessively drained soils on floodplains and alluvial fans.

Since FEMA maps were not available for Forest lands, the Forest followed the direction in Executive Order 11988 on Floodplain Management (1977). This order states that “if such maps are not available, the agency shall make a determination  of the location of the floodplain based on the best available information.”   On National Forest System lands, floodplain soils (Riverwash and Soboba series) are present along the stream channels in Silverado, Trabuco, Holy Jim and San Juan Canyons. A map of the extent of floodplain soils for Holy Jim and Trabuco Creeks is provided in Figure 1.
Figure 1.  Extent of floodplain soils mapped by the USDA Soil Conservation Service in 1978.

Figure 1 indicates that the roads and recreational residence in both Trabuco and Holy Jim Canyons were constructed within the currently mapped 100 year flood plain.  Removal of the dams will not change this fact.

4.2  Request for document that mapped 100-year floodplain
Response to 4.2 – No formal mapping of the 100-year floodplain has been completed by the Federal Emergency Management Agency (FEMA) on National Forest System lands within the project areas.  However, the USDA Soil Service mapped the floodplain soils in each of the project area canyons in 1978.  The extent of these mapped soils provides an accurate depiction of the present day 100-year floodplain due to the constraints of the canyon geomorphology.  See response 4.1 for more detail on this subject.

4.3 Removal of dams will increase flood risk to cabins/historic cabins, roads, trails, trees, retaining walls.
GO TAKE A LOOK AT THE TRAILS today flooding and historic storms have brought down debris Studies cough cough a few rangers and a cell phone camera do not take a look at what changed from 2013 study during drought and current conditions

Response to 4.3 – The dams, built by Orange County between the 1940s and mid-1970s, were not built to provide for flood protection and were never operated to provide for flood control.  Each dam had a wooden gate that was placed in the center of the dam each spring to retain water through the summer.  Gates were then removed in the fall to allow water to flow through the dam during winter storms.  Therefore, removal of dams would not impact the risk to future flooding during major storm events. Five of the dams in Holy Jim Creek were built or rebuilt without central gates; these dams have filled with sediment and do not store water. Figure 2 shows flood damage in Trabuco Canyon from the winter of 1937-1938. There have been other flood events that have damaged infrastructure during the time after the dams were constructed, primarily in 1969 when 6 cabins washed away and another 5 cabins were undermined or damaged.  These canyons are highly dynamic and flashy systems that developed naturally through episodic flooding events over time.
Figure 2.  Historical photo from the winter of 1937 showing flood damage in Trabuco Canyon after  a significant winter rainfall event.  Photo courtesy of James Newland.

A higher risk of increased flooding would occur if the dams are left in place.  Over time, unmaintained dams have the potential to fail.  This failure could cause stream channel avulsion during higher flows which could potentially damage established infrastructure. 
4.4  Removal of dams will increase erosion risks

Response to 4.4 – In the short term, removal of the dams would promote increased erosion of the material that has been trapped behind the dams.  Because of this, we would remove a set of dams in areas with higher values at risk (Holy Jim Canyon) systematically and let the material work itself through the system before another set number of dams would be removed.  The removal would take at least 3 years depending on the reworking of the stream due to precipitation over that time.   The alternative to systematically removing the dams would be to let them fail naturally.  There is no intention by Orange County to maintain these dams in the future.  Because of this they will inevitably fail.  When this happens it is probable the trapped material would be released downstream at once.  Depending on the magnitude of the storm and failure of the dams, allowing this to happen could have significant impacts to downstream infrastructure including cabins and roads.
4.5  Removal of dams will release excessive/dangerous amounts of sediment
Response to 4.5 – See response to 4.4.

4.6  Removal of dams will cause catastrophic flows of water and sediment
Response to 4.6 – See response to 4.4  

4.7  Removal of dams will impact the performance of nearby wells needed for domestic water supply and firefighting
Are you crazy with this lie? AS the course of water flow is changed, and DIVERTED the Forest Service is moving the water to someone else. Are you sending water to Moulton Ranch? Are you giving water to the Water District?
Response to 4.7 – Wells used by residential tract residents in Holy Jim Canyon are solely groundwater wells.  There are no surface water intakes that would be affected by the anticipated short term sediment release.  Groundwater recharge in these areas could only be impacted by drought and/or water diversions.  To our knowledge, there are no significant upstream diversions impacting groundwater recharge in the Holy Jim area.
As for firefighting, we have identified reliable water source points in each of the Canyons should water be needed.  The plan does not include any of the pools created by the existing dams.  

4.8  Hydrology report underestimates the nature of storms in SoCal, specifically El Nino events; commenter implies that cabin owners will be at increased risk during these storms if dams are removed.

Response to 4.8 – Holy Jim and Trabuco Canyons are highly dynamic and flashy systems that developed through episodic flooding events over time.  This is evidenced by the alluvial fan where the cabins in lower Holy Jim are located.  The reason that this area is flatter and wider than the rest of the Holy Jim Canyon is because the gradient drops once the channel leaves the confined section of Holy Jim and enters the recreational residence area. In less confined areas of a channel, stream velocity and carrying capacity decreases, resulting in sediment deposition.   It is natural for the channel to drop material here and subsequently migrate back and forth across the channel bottom as evidenced in both Holy Jim and Trabuco during past flooding events such as in 1937, 1965, 1969, 1998, 2008, and 2010. 

The stream channel through the cabin area has been channelized in the past in an attempt to protect the cabins in the area.  This channelization creates more energy downstream of the cabins and contributes to the damage that occurs in Trabuco Canyon, specifically Trabuco Canyon Road after significant storm events.  Further, the dams were never intended to protect the cabins from flooding.  This is evidenced by a video provided by recreational residence owner Milligan where the water is completely overtopping a dam just above the cabins.  If it was a flood control structure the water would be captured and released into the system at a later time.
The bottom line, from a hydrology and geomorphology perspective, is that the recreational residence tracts in Holy Jim are located in an area that over geologic time is extremely dynamic.  The current dams are not protecting cabins from flooding or stream channel avulsion.  The bigger risk is the fact that these aging non-flood control dams, of which are not being maintained and will not be maintained in the future, will fail someday.  When that happens the material that has been trapped upstream of the cabins would be released into the system with potentially damaging effects.  This represents a much larger risk to the cabins and downstream infrastructure than if the Forest Service systematically removes them using sound scientific and engineering principles. 

4.9    Removing dams will create a downstream Venturi effect that will increase scouring and erosion, endanger cabins and roads, trails, trees
Do you want to provide flood insurance and allow rebuilding of the cabins after you destroy them?
Response to 4.9 – The Venturi effect is the reduction in fluid pressure that results when   a fluid flows through a constricted section of pipe.  Because this project does not involve fluid in a pipe, the Venturi principle is not valid for this project. The dams funnel and channel stream flow, creating a scouring effect downstream. Removal of the dams will decrease this scouring action.

4.10 Photos from 1969 demonstrate destructive potential of floods- hydrology report needs to consider this.

Response to 4.10 – The photos provided by Mr. Milligan illustrate the dynamic nature of the stream systems in the Santa Ana Mountains.  When significant precipitation occurs, the streams become flashy, dynamic and dangerous.  The photos illustrate that infrastructure becomes vulnerable and that the existing dams do not provide any protection when heavy precipitation and subsequent flooding occurs.  A mention of the 1969 event was updated in the hydrology specialist report.

4.11 Some of the cabins are historic.  They will be at risk and may be destroyed if dams are removed.

Response to 4.11 – The dams, built by Orange County between the 1940s and mid-1970s, were not built to provide for flood control and were never operated to provide for flood control.  There is currently no flood control for any of the cabins in the Holy Jim, Trabuco, or San Juan cabin tract areas.  Naturally, these streams are highly dynamic systems with the potential to produce large floods that could damage local infrastructure as evidenced by past events.  The removal of dams will not change this risk into the future.   Forest records indicate that approximately 21 cabins in the Holy Jim and Trabuco tracts have been lost to floods since the 1940’s -  approximately 15 cabins in the 1937/1938 floods, and 6 in the 1969 flood.  There is a high baseline risk of flooding in this area that is not influenced or affected by the proposed action. 

5          Biological concerns:

5.1  Removal of dams may harm Sticky Dudleya  and Ocellated Humboldt Lily plants; these should be salvaged from work areas  This was not done. Plants are gone. Evidence of weed wacking.

Response to 5.1.  The proposed action has been revised to include salvage and replanting of these species, see Section 2.1.1 of EA, General Resource Protection measures, item 7.

5.2  Removal of dams will not benefit steelhead as they are not currently present; steelhead will not recolonize these streams – impossible to create  a migration route for them

Response to 5.2.  The impediments created by multiple fish-passage barriers within each creek are a concern addressed by the Southern California Steelhead Recovery Plan (NMFS 2011).  We fully recognize that restoring suitable habitat conditions for steelhead migration, spawning, and rearing of young will require multiple management actions by several agencies over many years.  The physical modification of road crossings and other barriers has been listed by NMFS as a critical recovery action for this geographic area.  NMFS has indicated a plan to address impassable barriers in the downstream portions of the creeks.  The Forest Service’s plan is to implement this recovery action within our own boundaries, as funding permits, which supports both the recovery plan as well as our management plan.  Additional discussion of this concern appears in section 3.2.1 of the EA.

5.3  No evidence that steelhead ever occupied Trabuco Creek – trout there were planted.

Reponse to 5.3.  The National Marine Fisheries Service performed an extensive review of Southern California Steelhead for the 2012 Recovery Plan in which they determined that tributaries within the Southern California Steelhead Recovery Planning Area, including the San Juan Creek/Arroyo Trabuco watershed, were historically occupied and have the potential to support steelhead in the future once man-made barriers are removed.    Additional discussion of this concern appears in section 3.2.1 of the EA. NOPE

5.4  Removal of dams will not benefit steelhead unless downstream barriers are also removed (Four Trabuco Ck road crossings, et al.) implementation of dam removal should be incremental, should be delayed and implemented only after downstream barriers are removed.

Response to 5.4. The Southern California Steelhead Recovery Planning Area includes portions of the coastal watersheds that are currently inaccessible to steelhead due to man-made barriers.  The National Marine Fisheries Service has identified physical modification of barriers such as road crossings, highways, and railways as a critical recovery action in the Recovery Plan (NMFS 2011).  Modification of these fish passage barriers is a necessary first step to providing functional habitat to steelhead and other native fish.  In recognition of this, the Forest Service is working proactively to remove the barriers from our lands as funding is available.  Additional discussion of this concern appears in section 3.2.1 of the EA.

5.5  Trabuco/Holy Jim do not have enough water to support a persistent resident population of steelhead .

Response to 5.5.  The Southern California Steelhead Recovery Planning Area (NMFS 2011) includes portions of the coastal watersheds that are only seasonally accessible to migrating steelhead.  While it is true that due to relatively low average rainfall in the region many of the drainages are seasonally dry or can have extensive dry portions, steelhead will attempt to move upstream into upper portions of a stream when water flow conditions are favorable for migration.  Therefore, we will work to improve creek habitat on the Forest in preparation for the years when conditions support movement to and use of the habitat by steelhead.  Additional discussion of this concern appears in section 3.2.1 of the EA.

5.6  Forest vegetation is already changing due to drier climate (eg death of alder trees), drier conditions will make it difficult for steelhead to access Trabuco Ck. 
Response to 5.6.  The Mediterranean climate of southern California has long dry summers, and brief winters with short, intense storms.  Steelhead have been a part of this ecosystem for a very long time and have adapted to the “flashy” hydrologic conditions.  While climate change predictions suggest storm and drought cycles may be amplified in the future, steelhead will have opportunities to migrate upstream in tributaries when the flow conditions are favorable (NMFS 2011).  Additionally, the ability of the species to switch between multiple life-history strategies (freshwater residency and/or anadromous migration) will be an important adaptive response to changing, highly variable environmental conditions. Additional discussion of this concern appears in section 3.2.1 of the EA.

5.7  Removal of dams in Holy Jim/Trabuco will not benefit steelhead or arroyo toad. 

Response to 5.7.  Over time, the dam removal will benefit both of these species as release of sand and gravel from the dams will improve the condition of spawning or breeding habitat for these species downstream of the project area, as well as improving aquatic organism passage within and upstream of the project area. Please see section 3.2.2 of EA. 

5.8  Removal of dams will not benefit arroyo chub.

Removal of dams will substantially benefit arroyo chub as their populations are currently fragmented by the dams.  Please see sections 3.2.2 of EA and response to comment 5.15.

5.9  Arroyo chubs and pond turtles are not present in Trabuco/Holy Jim Creek.
pond turtles ARE present, yellow legged frogs and southwestern Willow Flycatchers

Response to 5.9. Forest records and range maps for these species indicate that there is occupied or potential habitat for these species in Trabuco and Holy Jim Creeks, so these species must be considered in the project analysis. 

5.10 There are no horned lizards in Trabuco Canyon.
Response to 5.9. Forest records and range maps for these species indicate that there is
occupied or potential habitat for these species in Trabuco and Holy Jim Creeks, so these
species must be considered in the project analysis. 

5.11 Removal of dams will harm wildlife species such as migratory birds.

Response to 5.11. The project may result in a short term disturbance to migratory birds as described in the EA.  Effects on migratory birds will be minimized by completing project work in the fall when few birds are nesting.  Migratory birds will experience a long-term benefit from the project as the streamside habitat recovers after removal of dams.   Please see section 3.2.4 of EA.

5.12 Fish ladders should be installed to allow for fish movement.
Response to 5.12.  Please see the analysis of Alternative 3, in section 2.3 of EA. Fish ladders are not feasible because they do not meet the purpose and need of the project, and they are extremely expensive.
5.13 Special use permittees (rec cabin owners) protect the native wildlife such as newts, snakes, lizards, and have built small dams to preserve pool habitat for California tree frog tadpoles.
Response to 5.13.  The Forest appreciates the efforts of recreation cabin owners to protect wildlife.  However, dam construction is not allowed by the recreation cabin special use permits and requires state and federal permits. 
5.14 Dams are a refuge for wildlife including snakes, lizards, frogs and newts.

Response to 5.14.  The stream will continue to have pools and rocky banks after dam removal, which will provide habitat and refuges for these species. Please see Section 3.1.2 of EA for further information. 

5.15  Trout, fish, salamanders do not need to move up and downstream to maintain populations.
Response to 5.15 - Fish and other aquatic wildlife do need to travel up and downstream to seek out suitable mates, breeding habitat, and feeding habitat.  As summarized in the EA, Section 3.2.2, and in Hoffman (2007);
Movement is an essential mechanism by which mobile animals acquire the
resources necessary for the successful completion of their life-cycles (Greenwood and
Swingland 1983; Dingle 1996). It also plays a crucial role in how animals are distributed
across the landscape and the persistence of populations and species (Ricklefs 1990;Fausch et al. 2006).

6        Hazardous Materials concerns: 

6.1 Removal of dams will release arsenic and mercury that were used in Holy Jim placer mine operations.
LIES The wells up off Ortega have arsenic, heavy metals and toluene solvents poisoning the water. They never tested this. Demonstrate you tested the metals used in structure. Mining permits did exist here and still do today. 

Response to 6.1: The Hydrology Report discusses in detail the beneficial uses and State of California 303d listing status of waters near the project area. Holy Jim Canyon is not, nor has it been, listed by the state for any water quality issues related to arsenic or mercury. Although the Forest does not have records of historic mining, some small scale mine tailings have been observed, which indicates that mining could have occurred at some time. However, because there have not been elevated mercury or arsenic levels in Holy Jim Canyon historically (no historic 303d listing), there is no evidence that there would be elevated levels of arsenic or mercury resulting from project implementation in the near future.

6.2 – Commenter states that protective measures such as spill prevention will not be adhered to.

Response to 6.2:  Project Design Features, including best management practices (BMPs), site-specific mitigations, and Forest Plan Standards and Guidelines are an integral part of implementing the project.

BMPs have been designed to protect and restore watershed resources. Implementation of BMPs ensures adherence to the Federal Clean Water Act. All federal agencies must comply with the provisions of the Clean Water Act, which regulates forest management activities near federal waters and riparian areas. Additionally, the 2005 Cleveland Forest Plan directs water quality to be maintained and improved through the use of state certified and Environmental Protection Agency (EPA)-approved BMPs. The design features and BMPs associated with the proposed action ensure that Sections 208 and 319 of the Federal Clean Water Act (PL 92-500) and the guidelines established by the Santa Ana and San Diego Regional Water Quality Control Boards (California Regional Water Quality Control Board, Santa Ana River Basin, 2008, California Regional Water Quality Control Board San Diego, 1994, amended 2011) are met.

Spill prevention and containment measures are required to be in compliance with the National Best Management Practices (BMPs) AqEco-2, which states “…Promptly install and appropriately maintain spill prevention and containment measures…” (USDA, 2012). The EA discusses water quality (chemical contamination) on page 28-29 and states that BMPs would be implemented as part of the project specifications.

Overall, to be in compliance with the Federal Clean Water Act, BMP implementation including spill prevention is mandatory.

7        Fire management issues:

7.1 – Removal of dams will prevent use of stream pools for firefighting efforts as pools will fill with sediment

Response to 7.1-  The dams have central gaps or openings where gates were once placed.  The gates have not been in use for 20 years or more, and the dams do not store water.  Some dams have plunge pools downstream; after dam removal pool locations may shift but pools will still be present and will be available for emergency firefighting. In general other water sources such as water tanks, or aerial drops of water from nearby lakes, are the preferred sources of water for firefighting. See Hydrology report and section 3.1.2 of EA  for further details. 

8        Safety concerns:

8.1 – Concern that use of explosives to demolish dams will damage cabins and adjacent roads in Holy Jim/Trabuco Creek.  What actions will be taken to protect cabins and facilities? 

Response to 8.1 -  The project includes several measures to protect cabins and facilities. See expanded description of proposed action, Section 2.1 which describes using a phased approach to allow gradual release of sediment at Holy Jim Creek, avoiding use of explosives near roads and structures at Holy Jim Creek, and preparing detailed engineering designs for demolition of dams near roads and structures. 

8.2 – There are no safety hazards associated with recreational activity on and around dams.

Response to 8.2.  Historically, when dams were in operation and seasonal gates were installed, there were several serious injuries associated with people jumping or diving from the dams.  Since the county stopped installing the gates, these problems have decreased but there is still potential for people to climb on the dams and jump or fall from these structures.  Please see section 3.3.1 of EA.

9        General support for proposed action. 

9.1  In favor of removing dams to restore natural flows and replenish beaches downstream

9.2  Supports removing dams which are useless infrastructure that encourages graffiti.

9.3  Supports removing dams to restore riparian vegetation and fauna

Response to 9.1, 9.2. 9.3 -  Thank you for these comments, they support the discussion in the Environmental Assessment.

10    Other concerns: 

10.1- Question about desired condition for Silverado Place (EA p. 7) – what communities are

      Response to 10.1 – This phrase refers to providing an open space area that is a refuge for   human visitors.

10.2- Request to change the order of items in project description – p 11 and 13- move up  items regarding equipment cleaning to top of  list.  

Response to 10.2 – This change has been made and items were re-organized for clarity, see Section 2.1.1 of  Environmental Assessment

11    Comments outside the scope of current analysis or already decided by law or regulation:

11.1   Concern about the maintenance level of Trabuco Creek Road.  Use funding to    maintain road.

Response to 11. 1: The Forest is aware of maintenance concerns for Trabuco
Creek road.  This issue is beyond the scope of the current project and will be
addressed in a subsequent analysis. The funding that is available for dam removal cannot  be used for road maintenance, which is funded under a different authority.

     11.2  When will effects of Trabuco Creek Road on stream habitat be addressed.

Response to 11. 2: The Forest is aware of concerns about the effects of Trabuco Creek Road on stream habitat.   This issue is beyond the scope of the current project and will be
addressed in a subsequent analysis.

11.3 Concern about the forest’s arundo removal project and arundo piles near project area.
Response to 11.3.  The weed removal project was addressed under a separate Environmental Assessment, and is outside the scope of the current analysis.

11.4 Concern about water rights for cabin owners.
Response to 11.4.  Water rights are administered by the State of California; this concern is outside of the scope of the current analysis.

11.5 Concern about the impacts of human population growth.

Response to 11.5 -  The Forest does not have the authority to regulate population growth; this concern is outside of the scope of the current  analysis.

11.6 Request for additional time to submit comments.

Response to 11.6. The length of the comment period is set by the Code of Federal Regulations, which does not allow for extensions. 

11.7 Removal of dams will eliminate fish stocking/fishing opportunities.

Response to 11.7.  Fish stocking is under the authority of the California Department of Fish and Wildlife; they are aware of this project and support dam removal. See CDFW’s website regarding fish passage at

11.8 Project work should focus on San Mateo Creek.
Response to 11.8.  There are no dams in San Mateo Creek on National Forest System lands.  San Mateo Creek is not part of the current analysis.

11.9 One commenter indicated that he should be hired under contract for the environmental analysis and dam removal work.

Response to 11.9 -  Any work that is contracted is subject to competitive bidding;  this is required by Federal Acquisitions Regulations.  

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