Tuolumne River Dam Licensing
Please Submit Written Comments by April 12
Draft Environmental Impact Statement
About FERC Licensing
The Federal Energy Regulatory Commission (FERC) is responsible for licensing dams that generate hydroelectricity. On the Tuolumne River, Don Pedro Dam – owned and operated by the Modesto and Turlock Irrigation Districts (MID/TID) – received its original license in 1966. 50 years later (2016) it was scheduled to be relicensed. The process has taken longer than expected because in 2012 FERC determined that La Grange Dam also required a license. La Grange is a smaller, older dam two miles downstream of Don Pedro. The licensing of La Grange is important because MID/TID had previously argued that studying fish passage (moving salmon and steelhead above Don Pedro Dam to spawn in the upper Tuolumne) should not be required since La Grange Dam is what actually blocks their migration.
Problems with the DEIS
FERC’s Draft Environmental Impact Statement (DEIS) for the two dams is very disappointing for the following reasons:
- It does not address problems caused by the construction and operation of the dams. Instead, it focuses on not making conditions worse moving forward vs. improving existing conditions.
- It does not acknowledge the California Water Resources Control Board’s recent adoption of new flow standards for the Tuolumne and other rivers through the Bay Delta Water Quality Control Plan. The Water Board is required to issue a water quality certification in the licensing process, so the DEIS should plan for the new standards.
- It fails to respond to many issues raised by resource agencies and conservation organizations and does not adequately study alternatives presented by those groups.
Submitting Written Comments
Your written comments will help build a case for requirements that will actually help restore the Tuolumne River. The biggest flaw in the DEIS is that it fails to incorporate adequate instream flows.
Written comments are due by 2 pm on Friday, April 12, 2019. For instructions on how to file comments, please click here.
Begin by introducing yourself. Why is this issue important to you? Perhaps you enjoy boating, fishing, swimming or bird watching in or along the Tuolumne River. Do you have information to share about fish and wildlife, recreation, water quality, personal observations or related issues?
Consider including some of the following talking points.
- Since New Don Pedro Dam was first licensed in 1966, major federal environmental legislation has been enacted. The new license should require dam operations to conform to modern laws. These laws include a revision to the Federal Power Act that now requires that recreational and aquatic uses get equal treatment with power and water supply. The new license must also meet the requirements of the Clean Water Act.
- The FERC staff alternative falls short of what science tells us is necessary to protect and restore the Tuolumne. In 2010, the California Water Resources Control Board issued a report titled Development of Flow Criteria for the Sacramento-San Joaquin Delta Ecosystem that determined that approximately 60% of unimpaired flow between February and June would be fully protective of fish and wildlife in the lower San Joaquin River and its three major tributaries, including the Tuolumne. On December 12, 2018, the State Water Board adopted new instream flow standards of 30-50% of unimpaired flow between February and June, starting at 40%. The Irrigation Districts, San Francisco and FERC propose just over 20%.
- Low flows in the populated areas along the lower Tuolumne River have a negative impact on recreation. Many residents are low-income and don’t have the luxury of traveling long distances to enjoy rivers. Low flows make the river ugly and unpleasant to be near. Low flows create poor conditions for swimming, fishing, and boating. The growth of invasive water hyacinth during low flows makes these problems worse.
- Low river flows make it hard for fish to swim upstream and downstream. Low flows concentrate pollution, raise water temperature, decrease dissolved oxygen, and make it hard for salmon coming from the ocean to find the river.
- Spring flows should be high enough to get water onto floodplains. Small salmon grow faster and more safely in floodplains. Higher flows in the spring also are necessary for juvenile fish to survive their swim to the ocean.
- Before New Don Pedro Dam was constructed, the Tuolumne hosted well over 100,000 spawning salmon. In recent years, the number has dropped to just a few thousand, or even as low as a few hundred.
- Current management of the Tuolumne favors non-native species over native fish. Bass evolved in ecosystems featuring slow-moving, warm water, similar to current conditions in the Tuolumne. Salmon and steelhead depend on faster-moving, cold rivers. Until we address the extreme habitat shift humans have created, non-natives will continue to outcompete (and eat) native fish.
- The commercial salmon fishery in California is on the brink. The salmon population was so low in 2008 and 2009 that the commercial fishing season had to be canceled, resulting in the loss of more than 2,200 jobs and $255 million in annual revenue.
- The FERC staff alternative embraces non-flow measures like gravel placement similar in scope to measures that failed in the past. The settlement agreement negotiated by the State of California, water agencies and conservation groups in 1995 failed to improve conditions in the Tuolumne. In fact, conditions have gotten worse. What is needed is greater investment in non-flow measures combined with adequate flows.
- The construction of New Don Pedro Dam and Reservoir left an excellent whitewater boating take-out for the upper Tuolumne River under water. The current take-out at Ward’s Ferry Bridge is crowded and dangerous. The federally-designated “Wild and Scenic” Tuolumne River deserves a safe and efficient take-out.
- Higher flows and a strong local economy can be successful together. Through better management of snowmelt, water-efficient irrigation practices, and better crop selection, farmers can grow more food with less water. A pilot pressurized irrigation system implemented by the South San Joaquin Water District— just north of the Tuolumne – reduced water demand by 30% while increasing crop yields by 30%.
- In the San Francisco Public Utilities Commission (SFPUC) service area, water use decreased by 30% between 2006 and 2016 as a result of water conservation. New technologies and practices are becoming available every year that can increase water use efficiency and bring new water supplies online.
For more information, email Peter@Tuolumne.org.