May 1, 2006
U.S. Army Corps of Engineers
State College Field Office
1631 South Atherton Street, Suit 102
State College, PA 16801
Attn: Amy Elliot
Dear Ms. Elliot:
On behalf of the Officers and Directors of the Greater Wyoming Valley Audubon Society (GWVAS), I thank the Corps of Engineers and the Pennsylvania Department of Environmental Protection for providing the public with this opportunity to comment on the Luzerne County Flood Protection Authority's application for permits to construct an inflatable dam in the Susquehanna River in Wilkes-Barre, Pennsylvania (CENAB-OP-RPA(WILKES-BARRE INFLATABLE STRUCTURE)03-01240-13). The following comments are specific to the Dam Permit Application and Supporting Documentation. I would appreciate your including these comments with any and all comments that the GWVAS has supplied concerning this project.
The GWVAS has been on record as opposed to the inflatable dam since 1994, and we remain opposed to the dam. We have commented extensively on each phase of the dam project, and we have submitted comments to various state and federal agencies when we have deemed such comments appropriate. Our opposition to the dam is based upon a variety of concerns relating to aquatic and terrestrial wildlife and its habitat, public health and safety, financial responsibility, recreational opportunities, and the potential for economic development. After having perused the applicant's Dam Permit Application and Supporting Documentation, we have discovered a number of deficiencies and inconsistencies that we herein identify and cite as reasons for denial of such permits.
Again, thank you for the opportunity to express our views, and thank you for considering our comments.
Sincerely,
Robert Wasilewski, President
Greater Wyoming Valley Audubon Society
Greater Wyoming Valley Audubon Society
Testimony for U.S. Army Corps of Engineers and Pennsylvania Department of Environmental Protection Public Hearing Regarding Luzerne County Flood Protection Authority's Application to Discharge Dredge or Fill Material into the Susquehanna River in Order to Construct an Inflatable Dam in the Susquehanna River in Wilkes-Barre, Luzerne County, Pennsylvania
May 1, 2006
Robert Wasilewski, President
Greater Wyoming Valley Audubon Society
The Luzerne County Flood Protection Authority (LCFPA), herein known as the "applicant," "has proposed the construction of an inflatable dam as a means of revitalizing interest in the Susquehanna River in Wilkes-Barre and the surrounding communities through new recreation, scenic and economic opportunities. The inflatable dam and associated recreational facilities are part of the mitigation plan for the Wyoming Valley Levee Raising Project." The applicant states in its Dam Permit Application and Supporting Documentation that "Clean Water Act Section 404(b)(1) Guidelines (Guidelines) are the environmental standards by which all Section 404 permit applications are evaluated. A permit cannot be issued unless determined to be the Least Environmentally Damaging Practicable Alternative (LEDPA). Practicable alternatives are those alternatives that are 'available and capable of being done after taking into consideration cost, existing technology, and logistics in light of overall project purposes.' ...The purpose of the Wyoming Valley Inflatable Dam project is to (1) mitigate the intangible negative socio-economic impacts caused by the levee raising project, (2) provide economic development potential for the Wyoming Valley region, and (3) provide river-based recreational opportunities (USACE 1996)."
After considering four options in the Analysis of Practicable Alternatives (2.5) , including a No-Action (no dam) Alternative and three alternatives that simply consider different dam locations, the applicant rejected the No-Action Alternative on the basis that, while it does satisfy purposes (1) and (2) above, "it fails to adequately meet the requirements of the project's Purpose and Needs" by not including opportunities for water-based recreation. The applicant has concluded that an inflatable dam is the LEDPA.
According to the Wyoming Valley Inflatable Dam (WVID) Feasibility Study, "the feasibility of the inflatable dam is predicated on the assumption that the following four requirements would be addressed prior to construction of the dam project:
1. The water quality immediately upstream of the dam is improved.
2. Environmental concerns are carefully addressed.
3. A plan for riverfront development and operation is prepared and implemented.
4. Institutional arrangements for a waterfront district are established."
The project's viability is entirely contingent upon the eradication of sewage discharges upstream from the proposed dam site. Since such eradication is unlikely in the foreseeable future, the dam simply is not a viable option. The Feasibility Study further states that, "Without meaningful water quality improvements, the present conditions of the Susquehanna River at Wilkes-Barre limit recreational use of the proposed impoundment to those activities that do not involve significant primary contact.... Without addressing the CSO problem, the potential success of the desired water-based recreation activities and real economic development will be impaired." Hence, the inflatable dam will not satisfy purpose (3) as stated above, and therefore, according to the applicant's selection standards, the dam cannot be the LEDPA.
The applicant acknowledges that "The [Clean Water Act] Guidelines (40CFR 230.10(a)) specifically require that 'no discharge of dredged or fill material shall be permitted if there is a practicable alternative to the proposed discharge which would have less adverse impact on the aquatic ecosystem, so long as the alternative does not have other significant adverse environmental consequences.' A permit cannot be issued, therefore, unless determined to be the Least Environmentally Damaging Practicable Alternative (LEDPA) for the proposed discharge." Since a dam at the proposed location, or at any of the locations considered, cannot satisfy purpose (3), none of the alternatives that include a dam can serve as the LEDPA. This alone should warrant denial of the requested permits.
While the three dam alternatives' inability to satisfy the water-based recreation purpose should be sufficient to deny the permit request, we challenge the use of mitigation funds for the applicant's stated purpose of "provid[ing] economic development potential for the Wyoming Valley region." Mitigation need only replace what was lost; it need not create conditions that did not exist prior to the perceived loss. The levee raising project may have further hindered access to the River and may have further reduced the visibility of the River; the levee raising did not, however, hinder economic development in the Wyoming Valley. If the levee raising has had, or will have, any economic impact, then that impact could only have been, or could only be, positive due to the perceived increase in protection from flood damage to homes and businesses in the flood plain. Hence, there is no need to provide mitigation for something that has been enhanced by the levee raising project itself.
Below we provide further evidence for our argument that the LCFPA's request should be denied.
Appendix-Specific Comments
Appendix C
A Survey and Analysis of the Riparian Avian Community along the Susquehanna River, Wilkes-Barre, Pennsylvania
According to information provided in Appendix C, inundation of shorelines, islands, mudflats, and gravel bars will cause summering birds such as spotted sandpiper (Actitis macularia) and great egret (Ardea alba) to lose foraging areas, while breeding birds such as killdeer (Charadrius vociferus) will lose nesting habitat. In addition, summer migrants such as sandpipers and plovers will lose foraging and loafing habitat. Appendix C asserts that open water species, which include various waterfowl species, "may actually benefit from the increased pool area." However, these open water species all are listed as migrants. Since waterfowl migrations in Northeast Pennsylvania occur in early spring (March-April) and fall (October-November), the open water species observed are likely to have been seen during April according to the study survey methods. Hence, these species would not benefit from the impoundment because the dam would be deflated during the spring and fall waterfowl migration periods. By contrast, bank edge species such as American black duck (Anas rubripes), mallard (A. platyrhynchos), and wood duck (Aix sponsa), all of which are designated as breeders, would lose shallow-water foraging habitat since these species are dabblers (feed on shallow vegetation by upending) as well as shoreline nesting and loafing habitat, a loss that could be critical to the survival of precocial young. In addition, the wakes created by motor boats and jet skis could hinder nesting and/or the survival of young.
Appendix C notes that all species will be influenced by the increased human traffic. Increased disturbance of foraging and nesting species will have the "ultimate result of lowering productivity," and there are "no practical mitigation measures for most species since foraging birds may appear anywhere and nesting is occurring in June and early July when human river activities would be maximal."
Increased human disturbance and the loss of nesting and foraging habitat would negatively impact the avian communities in the project area and would diminish the area's wildlife watching potential, and hence its ecotourism potential. According to the U.S. Fish and Wildlife Service (2002), wildlife watching activities generated $40 billion in 2001. Given the revenue that wildlife watching and ecotourism can generate, actions that diminish such potential seem contrary to the project purpose of providing economic development potential for the Wyoming Valley region.
Appendix C thoroughly addresses possible impacts to nesting peregrine falcons (Falco peregrinus) in the project area, correctly noting that the Wilkes-Barre pair recently has nested (and currently is nesting) "directly within the area that will likely be the focus of summer activities permitted by construction of the inflatable dam." Appendix C further asserts that "the most sensitive period, hatching, should happen just before dam inflation." While hatching would likely occur well before the dam is inflated, fledging, an equally, and perhaps even more, sensitive period would occur after dam inflation. Personal observations suggest that adult peregrines become extremely defensive of the nest area in the days leading up to fledging. Furthermore, the presence or absence of predators (Humans surely are perceived as predators.) in the vicinity of the nest would very likely impact successful fledging as young birds with virtually no flight skills and even fewer landing skills attempt to reach the nearest perch on their initial attempts to leave the nest. Human disturbance during this period, therefore, could cause mortality if young birds fall into the river or are forced to accept perches that leave them vulnerable to predators. Human ignorance may also factor into fledgling peregrine mortality.
Although it may be possible to employ a modification of nestling period mitigation option (2), diverting boat traffic for perhaps up to 1-2 weeks to allow the young peregrines to successfully fledge and improve their flight skills to a degree that would allow them to easily flee from danger, the question arises as to how restrictions would be enforced. An additional concern is that restrictions on human activity at the beginning of the recreation season could draw undesirable attention to the birds and could even result in animosity against the peregrines among those who are forced to abide by the restrictions. This concern harkens back to the previously-cited human ignorance factor since animosity against the peregrines could result in injury or mortality to both nestlings/fledglings and adults.
One final concern that arises from Appendix C is based upon the conclusion that "Riparian forest species should not be affected by [the death of the riparian forest] since ground water levels are not expected to be high enough to cause root damage and thus death of riparian trees." This conclusion will be addressed below in comments on Appendix E and Appendix F.
Appendix E
Floodplain Groundwater Study
and
Appendix F
Indirect/Secondary & Cumulative Effects Report
Appendix E notes that the groundwater study found that 26% of the readings ranged to 1.50 feet (shallow root zone) below the ground surface and 20% ranged between 1.51 and 4.5 feet below the ground surface (deep root zone), indicating that 54% of the readings demonstrated that groundwater levels were below the root zone, which was assumed to range to approximately 4.50 feet below the ground surface. Since 54% of the readings indicated that groundwater levels ranged below the root zone, 46% indicated that groundwater levels ranged within the root zone. Hence, groundwater levels in approximately half of the project area fell within the root zone, suggesting that trees in approximately half of the project area could be affected by root inundation. Appendix E further notes that four of the piezometers that measured groundwater levels within the root zone were located within jurisdictional wetlands, and that two were located within 50 feet of a jurisdictional wetland. Appendix E therefore implies that, because the forest in these areas appeared healthy, elevated groundwater levels have little or no impact on the riparian forest. However, since the two piezometers that were located within 50 feet of jurisdictional wetlands produced groundwater readings within the root zone, this result could be interpreted to mean that groundwater levels elevated by the proposed impoundment could be more widespread than they normally would be without a dam, thereby potentially negatively impacting areas that otherwise would not be impacted.
Appendix E also notes that "river flow was considerably higher in the project area during 2004 [when the groundwater study was conducted] than average, resulting in an average river stage of 6.84 feet between March 3 and September 28, 2004. This level, according to Appendix E, would be "nearly 2.00 feet higher than would be expected when the WVID is inflated." The conclusion, therefore, is that the dam would have no impact on the riparian forest because it would maintain a river level that is below the average level of 2004. There are several problems with this conclusion.
First, average river stage may not be a good indicator since it offers no information about the duration of high flow events, nor does it offer any information about the effects of such events on wildlife. Averages are affected both by consistently similar data values and by extremely high or extremely low data values. In other words, the unusually high average river stages discussed in Appendix E could have resulted from prolonged and consistently high readings, or they could have been produced by single, short-lived high flow events. Indeed, this latter possibility seems to explain the average for September 2004 when river stage later in the month was elevated due to Hurricane Ivan, as noted in Appendix G Section 3.3. If high flow events during the summer months were common but relatively short lived, root systems may have been able to recover from one event before the next event occurred.
Second, according to Appendix F, Table 2-5, the mean river level was calculated using data for March through September. If the calculation is restricted to the river stage data for June, July, and August, the only full months during which the dam would be inflated, the mean river stage is 4.65 feet. Since, according to both Appendix E and Appendix F, the mean river stage during the study period in 2004 was 2.00 feet higher than it would be with the dam, the dam would produce a river stage of 4.84 feet (6.84 &endash; 2.00). Hence, the mean river stage for June, July, and August actually was below the level that would be maintained by the dam. Moreover, Table 2-5 in Appendix F indicates that the mean river stage for June was 4.20 feet and for July, 4.00 feet, or 0.64 foot and 0.84 foot, respectively, below the level that would be maintained by the dam. Only August, with a mean river stage of 5.76 feet, was above the level that would be maintained by the dam. However, it must be remembered that the study period in 2004, as reported in both Appendix E and Appendix F, experienced higher than normal rainfall and higher than normal river stages. Hence, under normal conditions, June, July, and August, and perhaps other months of the study period, all could be expected to see mean river stages that are below the level that would be maintained by the dam.
Third, Appendix E and Appendix F appear to assume that root systems in the shallow root zone likely were inundated during the study period, but that this inundation resulted in no ill effects to the riparian forest. This assumption leads to the conclusion that the proposed impoundment will have no negative impact on the riparian forest. However, no consideration appears to have been given to a forest's ability to withstand occasional stress without suffering long-term negative impacts. For example, some tree species are known to have the ability to withstand several years of defoliation by gypsy moth (Lymantria dispar) larvae before experiencing mortality. Hence, a riparian forest may be able to withstand several years of root inundation before experiencing mortality. The proposed dam, however, would cause root inundation every year that it is in operation. Just as a forest that experiences consecutively repeated years of gypsy moth defoliation eventually dies, so too could a forest whose major tree species experience consecutively repeated years of root inundation eventually die, a conclusion that is overlooked in the Dam Application Supporting Documentation. This oversight is critical because it directly influences the conclusions of the various studies (Appendix C, Appendix D, Appendix F) that address the proposed dam's effects on wildlife in the project area.
Appendix F Section 4.4.1 discusses potential cumulative impacts of the inflatable dam by category. Category-specific comments follow.
Animal Emigration
This subsection notes that increased human recreation in the project area may cause certain wildlife species to leave depending upon individual species' tolerance levels. The subsection states that, "It can also be assumed that the existing parks and human use activities in the project area have already initiated this impact response and that the WVID project would contribute to this impact category in an additive fashion and that contribution would not be adverse to any wildlife or fish taxa." However, no evidence to support the conclusion that the additive impact of 400,000 visitors per year would not be adverse.
Reduced Animal Reproduction
This subsection suggests that increased human traffic may have a positive effect on nesting birds by discouraging predation on nests near trails. This assumes that potential prey species will nest near heavily used trails, and it implies, by concluding that potential predators will expend more energy searching for prey and less on reproduction, that a reduction in predator reproduction is an acceptable consequence of increased human traffic. This might be fine for individuals of potential prey species but not for the overall ecosystem.
Habituation
Again, the conclusion here is that project-induced increased habituation will not have adverse impacts on wildlife, and again, no evidence is offered to support this conclusion. Habituation, however, makes wildlife more susceptible to harm stemming from ignorance and/or intentional actions.
Increased Predation
This subsection assumes, without project-specific supporting evidence, that predation such as raccoons on bird nests "has already been established in the project area due to the existing parks and trails." It should be noted, however, that, based upon the number of shells that are scattered along the river shore that something, probably raccoons, regularly preys upon mussels in the Susquehanna River. Since the dam will raise the river level, this food source could be lost, forcing the predators to seek other food sources. This could result in an artificially-induced increase in bird nest predation.
Modification of Activity Patterns
This subsection concludes that alterations in wildlife activity patterns, while additive as a result of the dam, will not represent an adverse impact. It notes that, in the Florida Keys, activity "buffer zones ranging from 100-180 meters are needed to avoid flushing perching water birds," and that "many predatory birds are known to alter their activity patterns to coincide with times of low human activity." In addition to the obvious negative impacts that altered activity patterns could have on nesting birds with hungry young, buffer zones of 100-180 meters could either severely restrict recreation such as water skiing and jet skiing or lead to conflicts and/or accidents among users.
4.4.2 Conclusions
The notable conclusion here is that, "It is probable that species with low tolerance for human interaction will flee the area during times of high human use but this may lead to larger populations of species that are more adept to tolerating human interactions." Hence, the dam and the associated visitation and attendant recreation will unnaturally alter the project area's community structure, a conclusion that suggests that a community composed of tolerant gray squirrels and American robins is an acceptable alternative to a truly wild community that features species such as Cooper's Hawks and red foxes. This conclusion also implies that an unnaturally altered community structure is just as valuable educationally and recreationally as is a truly wild community structure. We disagree.
This section also reiterates earlier suggestions that a management plan that selectively closes trails, creates buffer zones, outlines acceptable and unacceptable visitor behaviors, and develops educational programs to lessen the effects on wildlife could mitigate the dam's additive impacts. However, it offers no suggestion as to how regulations would be enforced or how educational programs would be implemented.
One final point worth noting about Appendix F is the recurring theme in Section 4.4.1 that "no studies were conducted" to reach the conclusions stated in this report.
Appendix G
Water Quality and Sediment Quality Inventory Report
In Section 4.1, Finding #4 states that, "Sewage discharges from CSOs primarily occur after heavy storm events which is when river flow would be highest. As previously stated, when river flow [is] high and water levels increase, the dam will be deflated allowing any sewage discharges to flow downstream preventing buildup behind the dam." This is not true. Sewage discharges, which during the summer months tend to occur after sudden heavy rains associated with thunderstorms, occur before the water level rises. Water level in the Wyoming Valley is more a result of precipitation in the watershed upstream from the Valley than it is of precipitation within the project area, whereas fecal and total coliform levels are more dependent upon local precipitation than precipitation upstream. Hence, coliform levels can rise before the water level rises or without the water level rising. Thus, the dam would not be deflated in time to prevent buildup. This will compound the problem of coliform contamination and increase the health risks to those using the river for activities such as water skiing and jet skiing.
In addition to possible buildup of coliform bacteria in the water column, fecal coliform bacteria have been shown to survive and to multiply in sewer-enriched sediments downstream from CSOs (Ellis and Yu 1995). Moreover, evidence that fecal coliform bacteria can survive in sediments (Burton and others 1987) at concentrations as high as 10 times those in overlying waters (Seyfried and others 1985) suggests that recreational disturbance of Susquehanna River sediments may increase fecal coliform densities in the water column to potentially excessive levels. Finally, several authors (Davies and others 1995; Howell and others 1996; Burton and others 1987; Seyfried and others 1985; Ellis and Yu 1995; Grimes 1975, 1980; McDonald and others 1982) have demonstrated that fecal coliform bacteria are capable of surviving, possibly for several months (Burton and others 1987) in sediments, and of being resuspended in the water column by a variety of disturbances. Indeed, Burton and others (1987) speculate that resuspension of sediment-sequestered organisms "may account, in part, for the erratic [fecal coliform] levels often encountered in water-monitoring programs." They suggest that "A more meaningful and accurate indication of water-quality conditions would be obtained by also monitoring indicator bacteria and virus levels in surface sediments." Appendix G failed to address the potential problem of bacteria accumulating in river sediments.
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In summary, the Officers and Directors of the Greater Wyoming Valley Audubon Society believe that the applicant's request for permits to construct an inflatable dam must be denied. The Application and Supporting Documentation contain inconsistencies and deficiencies that render the applicant's conclusions regarding the dam's environmental and health impacts inadequate to justify the granting of permits. Moreover, the applicant's own criteria for choosing the LEDPA exclude the dam as the LEDPA based upon the dam's inability to satisfy purpose (3), and hence, according to Clean Water Act Guidelines, "'no discharge of dredged or fill material shall be permitted if there is a practicable alternative to the proposed discharge which would have less adverse impact on the aquatic ecosystem, so long as the alternative does not have other significant adverse environmental consequences.' A permit cannot be issued, therefore, unless determined to be the Least Environmentally Damaging Practicable Alternative (LEDPA) for the proposed discharge." Nevertheless, we believe that a no-dam LEDPA does exist.
In the Alternatives Assessment section of the application, only one "No Action (no dam) Alternative" was considered, while each of the three other alternatives considered included the construction of a dam. The applicant quotes the Council on Environmental Quality (CEQ) as defining "reasonable alternatives" as "'those that are practical or feasible from a technical and economic standpoint and achieve the purpose and need of the project' (CEQ 1981). The applicant further states that the No Action Alternative, which is described as including the Wilkes-Barre riverfront development project, yields the least environmental impact and would be satisfactory in two of three categories (mitigate the intangible negative socio-economic impacts caused by the levee raising project and provide economic development potential for the Wyoming Valley Region). This alternative was deemed inadequate, and hence rejected, based only upon the No Action Alternative's inability to satisfy the water-based recreation category. However, the applicant failed to note that several of the proposed water-based recreational activities (fishing, canoeing, kayaking) already exist in the project area, and another activity, sculling, is possible without the dam.
We believe that the No Action Alternative, when augmented by the addition of improved boat launching facilities, would satisfy the third category in a more cost-effective and far less ecologically damaging way. For example, if new boat launching facilities were constructed on the Kingston side of the River near Pierce Street, fishermen, canoeists, kayakers, and scullers could easily access the River via the existing road over the levee. That area also currently provides adequate parking for automobiles with boat trailers. In addition to being far less costly both monetarily and ecologically, constructing such facilities near Pierce Street would reduce or eliminate vehicle traffic in Nesbitt Park, thereby resulting in a safer and more attractive Park. Moreover, new boat launching facilities in that area also would benefit emergency responders during river-rescue events.
The applicant's Alternatives Assessment appears to assume that the funds that have been appropriated for the dam must be spent in their entirety. To the contrary, we believe that less costly alternatives that fit the CEQ definition of "reasonable alternatives," such as that presented above, must be considered and evaluated for their ability to address the Project's Purpose and Need. We believe further that, since the applicant's stated purpose of the inflatable dam is to compensate residents for the reduced visibility, reduced access, and isolation from the River, the No Action Alternative with the augmentation described above would "compensate for these losses by creating incentives for revitalizing interest and opportunities along the river." In addition, we believe that a mitigation plan need only lessen the severity of the losses caused by the levee raising; a mitigation plan need not create new opportunities that did not previously exist, nor must it improve conditions to a degree that is far and above what existed prior to the purported loss.
The Officers and Directors of the GWVAS recommend that the U.S. Army Corps of Engineers and the Pennsylvania Department of Environmental Protection deny the LCFPA's request (CENAB-OP-RPA(WILKES-BARRE INFLATABLE STRUCTURE)03-01240-13). If decisions regarding the granting of permits will be delayed until a completed application is filed, then when the application finally is deemed complete, we request notification of the availability of the completed application and supporting materials, and we request that the U.S. Army Corps of Engineers and the Pennsylvania Department of Environmental Protection accept comments on the completed application.
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Additional Oral Comments Regarding Reports that the Dam Application Still is Incomplete:
However the shortcomings of the permit application might be addressed, the fact remains that poor water quality renders the Susquehanna River in the Wyoming Valley unsuitable for primary contact water-based recreation. Hence, the dam will not provide any water-based recreational opportunities beyond those that currently exist. Therefore, the dam cannot satisfy the levee raising's mitigation requirements, and it cannot be deemed the LEDPA. Thus, the dam permit request must be denied.
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Literature Cited
Burton GA, Gunnison D, Lanza GR. 1987. Survival of pathogenic bacteria in various freshwater sediments. Applied and Environmental Microbiology 53(4): 633-38.
Davies CM, Long JAH, Donald M, Ashbolt NJ. 1995. Survival of fecal microorganisms in marine and freshwater sediments. Applied and Environmental Microbiology 61(5): 1888-96.
Ellis JB, Yu W. 1995. Bacteriology of urban runoff: the combined sewer as a bacterial reactor and generator. Water Science Technology 31(7): 303-10.
Grimes DJ. 1975. Release of sediment-bound fecal coliforms by dredging. Applied Microbiology 29(1): 109-11.
Grimes DJ. 1980. Bacteriological water quality effects of hydraulically dredging contaminated upper Mississippi River bottom sediment. Applied and Environmental Microbiology 39(4): 782-89.
Howell JM, Coyne MS, Cornelius PL. 1996. Effect of sediment particle size and temperature on fecal bacteria mortality rates and the fecal coliform/fecal streptococci ratio. Journal of Environmental quality 25: 1216-20.
McDonald A, Kay D, Jenkins A. 1982. Generation of fecal and total coliform surges by stream flow manipulation in the absence of normal hydrometeorological stimuli. Applied and Environmental Microbiology 44(2): 292-300.
Seyfried PL, Tobin RS, Brown NE, Ness PF. 1985. A prospective study of swimming-related illness II. Morbidity and the microbiological quality of water. American Journal of Public Health 75(9): 1071-75.
U.S. Fish and Wildlife Service. 2002. 2001 National Survey of Hunting and Wildlife-Associated Recreation National Overview. http://library.fws.gov/nat_survey2001.pdf.