DPEIR Comment Excerpts
4 Pages
English
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DPEIR Comment Excerpts

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4 Pages
English

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Excerpts from Various Commentson the WSIP DPEIR(Prepared by Peter Drekmeier, Peter@Tuolumne.org, (415) 292-3531)California Department of Fish and Game"DFG is concerned that the current FERC required flow regime (i.e. PEIR’s CEQAbaseline conditions) may not be sufficient to prevent salmon populations in theTuolumne River from declining.  In fact, we have evidence demonstrating thatadult Tuolumne River fall-run Chinook salmon (Oncorhynchus tshawytscha)produced at a given spring flow has declined by about 50% (mean of 6,805recruits) since the FERC Settlement Agreement (FSA) was implemented in1996..."Page 4"...it is irrefutable that the actions of the SFPUC on the Tuolumne River at EarlyIntake, Cherry Valley Dam, and Hetch Hetchy, and Lake Eleanor reservoirsinfluence the water releases from the New Don Pedro Dam.  Increased diversionof waters from a river system which currently lacks sufficient flow to supportsustainable anadromous fisheries (including Federally Threatened steelhead)should be considered a significant cumulative impact...In this context we believethe WSIP has the potential to cause anadramous fish populations to drop belowself-sustaining levels and further reduce the number and restrict range FederalThreatened Central Valley steelhead – thereby requiring a finding of significanteffect [CCR Title 14, section 15065 (a)(1)]…Consequently, we respectfully requestthat the SFPUC use alternative water sources other than the Tuolumne riversystem ...

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Excerpts from Various Comments on the WSIP DPEIR (Prepared by Peter Drekmeier, Peter@Tuolumne.org, (415) 292-3531)
California Department of Fish and Game
"DFG is concerned that the current FERC required flow regime (i.e. PEIRs CEQA baseline conditions) may not be sufficient to prevent salmon populations in the Tuolumne River from declining.In fact, we have evidence demonstrating that adult Tuolumne River fall-run Chinook salmon (Oncorhynchus tshawytscha) produced at a given spring flow has declined by about 50% (mean of 6,805 recruits) since the FERC Settlement Agreement (FSA) was implemented in 1996..." Page 4
"...it is irrefutable that the actions of the SFPUC on the Tuolumne River at Early Intake, Cherry Valley Dam, and Hetch Hetchy, and Lake Eleanor reservoirs influence the water releases from the New Don Pedro Dam.Increased diversion of waters from a river system which currently lacks sufficient flow to support sustainable anadromous fisheries (including Federally Threatened steelhead) should be considered a significant cumulative impact...In this context we believe the WSIP has the potential to cause anadramous fish populations to drop below self-sustaining levels and further reduce the number and restrict range Federal Threatened Central Valley steelhead – thereby requiring a finding of significant effect [CCR Title 14, section 15065 (a)(1)]Consequently, we respectfully request that the SFPUC use alternative water sources other than the Tuolumne river system or implement water conservation measures to meet drought year demands and 2030 purchase requests..." Page 9
“we believe that if implemented as proposed, the WSIP would only exacerbate the current decline of anadromous fisheries in the Tuolumne River. Consequently, we respectfully request that the SFPUC use alternative water sources other than the Tuolumne river system or implement water conservation measures to meet drought year demands and 2030 purchase requests” Page 9
“We highlyrecommend that the SFPUC become more assertive with its wholesalecustomers for the purpose of conserving water and to ensure that growth isfeasible with respect to the water supply that is currently available." Page 10
USDA Forest Service
“At this point, due to the conceptual nature of the impact and mitigation that are described in the EIR, we favor an alternative which does not divert additional water which would affect the Stanislaus National Forest.”
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Modesto and Turlock Irrigation Districts (MID/TID)
Proposed Water Transfers
“Under Section 3.6.2 “Proposed Drought Water Supply” (pages 3-36 and 3-38) the draft PEIR envisions the transfer of 27,000 AF of water from the Districts to the CCSF.The Districts do not believe there is sufficient water within the watershed under dry conditions to support the transfers as described in the Draft PEIR. Itis inappropriate, therefore, to include the proposed transfer as a part of the CCSFs water supply plan.In addition, the Draft PEIRs discussion of the proposed water transfer from the Districts is (wholly) inadequate for CEQA purposes. Aproject-specific EIR is legally required to describe the proposed transfer in detail and to thoroughly assess all potential impacts.” Page 3
Water Quality Impairments may Worsen with Additional Diversions Proposed by WSIP
“The San Joaquin River system and its tributaries are currently listed as impaired for a variety of water quality parameters, with others being proposed.For example, the Department of Fish and Game has asked the Central Valley Regional Water Quality Control Board to “list” the San Joaquin River system as “impaired” for temperature, under Section 303(d) of the Clean Water Act.The Draft PEIR proposes increases in mean daily river temperature of 1-2 degrees Celcius during 15% of the months modeled (page 5.3.3-19), which would be significant, if the river system is already “impaired.”Any reductions in lower Tuolumne River flow could exacerbate current conditions.The impacts to the Tuolumne River or San Joaquin River water quality by the WSIP should be thoroughly evaluated and mitigation measures proposed where necessary to ensure that implementation of the WSIP would not result in reduced water quality or increased burdens on other water agencies within the San Joaquin River system.” Page 3
Additional Instream Flow Requirements
“In Section 3.7.1, page 3-43, the Draft PEIR states, “Although the fishery release requirements that FERC may impose in 2016 cannot be anticipated at this time, the CCSF assumes, for the purposes of the WSIP, that it will be able to continue its current agreement with TID and MID to pay them to provide all the additional water, if any, required for the fishery releases.”CCSF should not assume that it will be able to purchase water from the Districts to meet its future instream flow requirements.” Page 3
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San Luis & Delta-Mendota Water Authority, Westlands Water District and Kern County Water Agency
“The Draft PEIR suffers from three main legal deficiencies.First, the Draft PEIR fails to adequately analyze impacts of the WSIP caused by reduced inflow to the San Joaquin River and thus the Delta.Second, the Draft PEIR uses an outdated environmental baseline to evaluate impacts.Third, the Draft PEIR includes an alternatives analysis that relies upon speculation and questionable assumptions. To be legally sufficient, the Draft PEIR must be revised to address these inadequacies.” Page 5
“CEQA requires the evaluation of all reasonably foreseeable environmental impacts of a proposed projectTo satisfy that well established rule, the Draft PEIR must consider the effects of reduced San Joaquin River flow and Delta inflow attributableto the WSIP.The Draft PEIR does not do that.”
“The failure of the Draft PEIR to consider impacts with the San Joaquin River and the Delta is made more egregious by discussions in the Draft PEIR that suggest proper analyses of the impacts would show potential y significant effects. TheDraft PEIR recognizes that its water diversion will increase salinity levels of all affected waterways, (Draft PEIR, pp. 5.3.3_7, 5.3.3_20), and increase the temperature of the water in the San Joaquin River and the Delta.(Draft PEIR, pp. 5.3.3_14, 5.3.3_15_16, 5.3.3_19.)” Page 6
City of Hayward “We urge the SFPUC not to delay the certification of the PEIR and implementation of critical reliability projects due to issues related to future demand.” Cal Water “Cal Water strongly urges the SFPUC, Bay Area Water Supply and Conservation Association (BAWSCA) and other applicable local water agencies and organizations to consider ways of expanding the role of recycled water as a means of developing enhanced supply reliability throughout the San Francisco Bay area.” Assemblymembers Ira Ruskin and Sally Lieber
“The draft EIR has provoked concerns about additional diversion of water from the Tuolumne River.We urge you to undertake more comprehensive studies of the alternatives that minimize new diversions.”
“Implementation of more water conservation, efficiency, and recycling is the best way to lesson impacts on the Tuolumne River while promoting a sustainable water plan for the Bay Area.”
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RESOLUTIONS Tuolumne County Board of Supervisors ”Resolved, that the Tuolumne County Board of Supervisors unequivocally opposes the SFPUCs proposed diversion of an additional 25 million gallons of water a day from the Tuolumne River.”
“The County will seek and exercise the necessary legal remedies to see that no further water diversions occur from the Tuolumne River.”
San Francisco Board of Supervisors
”Resolved, that the San Francisco Board of Supervisors urges the SFPUC to explore and develop water supply options that will not divert more water from the Tuolumne River, including, but not limited to (1) aggressively and actively developing and encouraging water conservation and efficiency efforts, and (2) examining and developing programs and projects for the use of recycled water.”
Portola Valley Town Council
“Resolved, that the Town of Portola Valley strongly encourages the San Francisco Public Utilities Commission to focus its full attention on the seismic upgrades to the Hetch Hetchy water system and drop the controversial proposal to divert more water from the Tuolumne River.”
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