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San Francisco Public Utilities Commission
Correspondence Log
November 2, 2022 through November 19, 2022
Date Received From Subject
November 2, 2022 Dave Warner 186 Tuolumne Salmon Counted as of October 31
November 7, 2022 Peter Drekmeier Lower Tuolumne River Fall-run Chinook Salmon Background and
Update
Barry Nelson Lower Tuolumne River Fall-run
Chinook Salmon Background and
Update
November 8, 2022 Barry Nelson Lower Tuolumne River Fall-run Chinook Salmon Background and
Update
November 9, 2022 Peter Drekmeier Salmon Count Data Sources November 19, 2022 Tim Hutchins HHWP Releases Notification 11/10/2022
November 2, 2022
Re: 186 Tuolumne Salmon Counted as of October 31
Dear Commissioners,
Fishbio reports counting 186 Tuolumne salmon through November 1st. This may be an undercount because ac
cording to Fishbio, during the fall pulse flow period the fish count weir panels were submerged to allow for the massive amount of invasive water hyacinth upstream to pass through the weir site. The counting system is still operating during the pulse period but only able to count those salmon going through the passing chute.
As can be seen from the chart, on a season to date basis the 186 salmon is higher than the same time last year, but lower than all other years shown on the chart.
The large amount of invasive water hyacinth is another consequence of low flows and warm water on the Tuolumne.
You will note this chart is similar to the Total [water] Deliveries chart included in the drought conditions update slides in that it compares current year progress against prior years. Commissioner Maxwell and former Commissioner Harrington have both requested that staff regularly provide fish updates, which still has not yet been addressed. Please consider following up with staff to have such an update regularly provided. As 85% of our water supply comes from the Tuolumne, Commissioners should be kept current on the status of the Tuolumne, including salmon counts.
Best regards,
Dave Warner
3,072
2,123
1,061
579
6,072
-
1,000
2,000
3,000
4,000
5,000
6,000
7,000
1-Sep 1-Oct 1-Nov 1-Dec 1-Jan 1-Feb 1-Mar
Chinook Salmon Fish Passage
Source: FISHBIO
Stanislaus 2021
Tuolumne 2021
Tuolumne 2020
Tuolumne 2019
Tuolumne 2018
Tuolumne 2022
(red solid line)
265 to Nov 1
St
anislaus 2022
(red dotted line)
1,587 to Nov 1
OFFICES
San Francisco
Modesto
Sonora
Mailing Address
P.O. Box 3727
Sonora, CA 95370
Phone
(415) 882-7252
Website
www.tuolumne.org
BOARD MEMBERS
John Kreiter, Chair
Harrison “Hap” Dunning,
Vice Chair
Cindy Charles, Treasurer
Kerstyn Crumb, Secretary
Eric Heitz,
Chair Emeritus
Jose Borroel
Eddie Corwin
Bob Hackamack
Camille King
Marty McDonnell
Homero Mejia
John Nimmons
Eric Riemer
Marek Robinson
Bart Westcott
November 7, 2022
President Newsha Ajami and Commissioners
SFPUC
525 Golden Gate Ave.
San Francisco, CA 94102
Via Email
Re: Item 7c: Lower Tuolumne River Fall-run Chinook Salmon Background and Update.
Dear President Ajami and Commissioners:
It’s good to see an update on the condition of Tuolumne River salmon on your agenda. We hope this will become a regular item at SFPUC meetings.
Slide 4 titled “How do we know what’s happening with these fish” explains how juvenile salmon survival on the Tuolumne is measured using rotary screw traps (RSTs) to count baby fish at two locations as they outmigrate. These RST counts are used to determine mortality between Waterford and Grayson.
You’ll see from the table below that in the big water year of 2011, juvenile survival was much higher than in the other years. Note that following each year there is a C (critically dry), BN (below normal), AN (above normal), W (wet) or D (dry) to quantify precipitation and runoff conditions.
During most years, mortality was between 93% and 98%, but in 2011, the only wet year, mortality dropped to 74%. This is very telling. The graph shows unimpaired flow (in blue) for each of the six years represented in the table.
2 While the SFPUC and Modesto and Turlock Irrigation Districts (MID/TID) have no control over ocean conditions nor the Delta pumps, you have near full control over conditions on the Tuolumne. Your success at protecting and restoring the ecosystem can be measured by juvenile fish survival in the River.
California Fish and Game Code 5937 states, “The owner of any dam shall allow sufficient water at all times to pass through a fishway, or in the absence of a fishway, allow sufficient water to pass over, around or through the dam, to keep in good condition any fish that may be planted or exist below the dam.”
The SFPUC and MID/TID have failed to keep fish in good condition in the Tuolumne. The Tuolumne salmon population is worse off than in any other Central Valley river.
Following a 1995 FERC settlement agreement, MID/TID filled an in-river mining pit, called Special Run Pool 9, that was known to harbor largemouth bass, a non-native predator that feeds on juvenile native fish. The Irrigation Districts’ own post-project monitoring report acknowledged:
3 During extremely wet years, high flows can flush largemouth bass out of a stream, but typically a sufficient number of adults can find shelter in flooded areas to repopulate the stream during lower flow conditions. During the years following the flood, largemouth bass abundance was controlled by spring and summer flow conditions that were unfavorable for reproduction. Largemouth bass require low water velocities and warm water temperatures to reproduce.
The failure of the Special Run Pool 9 project demonstrates that the main problem on the Tuolumne is that the ecosystem has been altered in a way that favors non-native predators that evolved in slow moving, warm water over native species that evolved in faster moving, cold water. In the absence of adequate flows, non-flow measures are destined to fail.
Please accept the fact that voluntary agreements will not produce more fish with less water.
Higher flows are critical to the survival of fish populations in the Tuolumne. The ecosystem is on the brink of total collapse, and we’re running out of time.
Sincerely,
Peter Drekmeier
Policy Director
From: Barry Nelson
To: Commission
Cc: John McManus; Peter Drekmeier
Subject: For Commissioners Tomorrow - Agenda Item 7(c)
Date: Monday, November 7, 2022 7:48:30 PM
Attachments: Tuolumne Salmon Run Worst.png
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Donna - Can you share this graphic with the Commission for the discussion at tomorrow’s meeting during agenda item 7(c)? Thanks.
This graphic was presented by SFPUC staff at a previous Commision meeting. It shows progress toward the state and federal salmon restoration goal for the Bay-Delta ecosystem - which is doubling the naturally spawned salmon compared to the period from 1967-1991.
Note that this SFPUC graphic shows that the Tuolumne has the worst record of any Central
Valley river over the past several decades. That record is directly related to the fact that the Tuolumne has one of the lowest unimpaired flows of any Sierra River.
Barry Nelson
Western Water Strategies
510 340 1685
From: Barry Nelson
To: Commission
Cc: John McManus; Peter Drekmeier
Subject: Re: For Commissioners Tomorrow - Agenda Item 7(c) Date: Tuesday, November 8, 2022 11:58:13 AM
Attachments: Peer Review Executive Summary.pdf
Final Letter to SFPUC re peer review and Tuolumne VA 9-14-20.pdf Bay-Delta VA Analysis 9-1-22.pdf
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Donna - Here are some additional documents regarding agenda item 7(c) today that I hope you can share with the Commissioners. I’ll refer to some of these in my comments today. In particular, I thought the new commissioners might find these helpful to follow up our discussion. This packet includes:
- The executive summary of the August 2020 NMFS peer review of the fish population models that the SFPUC has used as the foundation of it’s position on flow issues. - A Sept. 2020 letter from NGOs requesting that the SFPUC respond to the NMFS peer review.
- An
op-ed by NRDC and GSSA.
- A SF Chronicle editorial
- An NGO fact sheet regarding the failed voluntary agreement (The SFPUC has not yet signed this VA package.
However, it appears likely that it will do so relatively soon.) Thanks.
Barry Nelson
Western Water Strategies
510 340 1685
On Nov 8, 2022, at 8:29 AM, Commission <
[email protected]> wrote:
Thank you,
Donna
From: Barry Nelson <
[email protected]> On Behalf Of Barry Nelson
Sent: Monday, November 7, 2022 7:48 PM
To: Commission <
[email protected]>
Cc: John McManus <[email protected]>; Peter Drekmeier <[email protected]>
Subject: For Commissioners Tomorrow - Agenda Item 7(c)
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Donna - Can you share this graphic with the Commission for the discussion at tomorrow’s meeting during agenda item 7(c)? Thanks.
This graphic was presented by SFPUC staff at a previous Commision meeting. It shows progress toward the state and federal salmon restoration goal for the Bay-Delta ecosystem - which is doubling the naturally spawned salmon compared to the period from 1967-1991.
Note that this SFPUC graphic shows that the Tuolumne has the worst record of any Central Valley river over the past several decades. That record is directly related to the fact that the Tuolumne has one of the lowest unimpaired flows of any Sierra River.
Barry Nelson
Western Water Strategies
510 340 1685
<image002.png>
Tuolumne Model Review ES-1 August 2020
Executive Summary
This report provide s an independent review of the Chinook salmon (Oncorhynchus tshawytscha) and O. mykiss population models developed by the Turlock Irrigation District and Modesto Irrigation District (collectively we refer to these as “the Districts”) . The models were designed to assess the extent to which the abundance of Chinook salmon and O. mykiss in the Tuolumne River may be affected by in-river factors, identify factors that influence life-stage specific production and critical life stages, and compare relative changes in smolt population size and smolt productivity between potential alternative management scenarios. The review team consisted of five scientists with expertise in salmonid ecology, populatio n dynamics, modeling, hydrology and engineering, geomorphology, sediment dynamics, and habitat restoration. Each member of the review team has over 35 years of professional experience.
We evaluated the models and supporting documents to determine if the m odels are usable and useful. That is, from our perspective, can the models be used to identify critical life stages, identify and evaluate life-stage-specific limiting factors, and compare relative changes in smolt population abundance and smolt productivity among alternative management scenarios? Given the large amount of information collected as part of the project, the models are used to help synthesize and distill the information into results that can be used to evaluate management scenarios. However, i t is important to point out that all models make simplifying assumptions . This ensures that to a certain degree all models are ultimately wrong or at least incomplete. We viewed the models in this context.
Our goal in this review was to determine if the models, their assumptions, and the data used to populate the models are adequate enough to make the m useful tools for evaluating management scenarios, and whether they were designed in a such manner that they can be easily used by the Districts and stakehold ers.
Our review was straightforward and included reviewing model and data reports prepared by the Districts along with scientific information from California’s Central Valley and other regions. As part of our review, we considered how the Districts incorpo rated the Viable Salmonid Population concept developed by National Oceanic and Atmospheric Administration (NOAA) Fisheries to define the essential characteristics of a viable salmon population . The concept is used in recovery planning for populations listed as threatened or endangered under the Endangered Species Act (ESA), with a focus on abundance, intrinsic productivity, and biological diversity. We also found it helpful to consider both the inputs and outputs of the Tuolumne population models within a c onventional stock-recruitment model. With considerable effort, we were able to evaluate model coding and run the models under different spawner escape ment levels and assumed smolt-to-adult return rates to understand modeled relationships. To improve the qu ality of our review, we submitted a letter requesting additional information and clarification regarding the models (Appendix A). Their responses help ed us in our review of the models and we greatly appreciated the quick response from 20200827-5055 FERC PDF (Unofficial) 8/26/2020 8:01:26 PM
Tuolumne Model Review ES-2 August 2020
the Districts and their consultants to our request (Appendix A). Finally, most members of the review team toured the lower Tuolumne River in January 2020 to gain a perspec tive of the Tuolumne River that is not available from reports .
Based on our review of the models, the supporting information, and other pertinent information, we conclude the following: 1) the three physical models developed to support the population mode ls are useful and usable; 2) the Chinook salmon population model is useful but not us able by all stakeholders; and 3) the O. mykiss population model is neither useful nor us able. Below, we summarize our reasons for these findings.
Physical Models
We found no significant issues with the three physical models that support the population models .
The Tuolumne River Operations Model represents observed operations relatively well; however, we recommend that an operations model with more capability and flexibility be used in the future, such as the RiverWare model that is commonly used by the U.S. Bureau of Reclamation for operational planning in complex river basins. The Don Pedro Reservoir Temperature Model results appear adequate for use in the Lower Tuolumne Ri ver Temperature Model, and the Lower Tuolumne River Temperature Model predictions are likely satisfactory for use in fish population modeling. We noted that the Lower Tuolumne River Temperature Model was not able to represent diurnal fluctuations accurately in some reaches of the river. This is likely due to unknown groundwater inflows or outflows and the pres ence of the special run pools that may act as a thermal buffer due to the large volume of water in the pools. Because the population models use daily average temperatures, the predictions from the Lower Tuolumne River Temperature Model are likely satisfact ory for use in fish population modeling.
Chinook Salmon Population Model
The Chinook salmon population model is a complex, spatially explicit, individual-based model that tracks each fish within the modeled population along the river on a daily basis. Impo rtantly, it is not a full life-cycle model, meaning that it makes no attempt to complete the life cycle of the surviving smolts. Therefore, it cannot predict equilibrium spawner abundance levels that would be expected to occur under a prescribed set of man agement actions. The model is written in the “R” statistical software package and we initially found it difficult to run, track, and alter different aspects of the inputs. The modeling reports were not helpful in this regard. Once we became familiar with t he model, it was easier to operate. We doubt that many stakeholders will find the model us able. From our perspective, given that this is the river, fish conservation, and fisheries management tool that will be used for the term of the Federal Energy Regula tory Commission (FERC) license, the Districts should make the Chinook salmon population model available to stakeholders if they have not already done so, and the stakeholders need to learn how to operate and use the model to assess tradeoffs between flow a lternatives. Model users would benefit by having the model developers 20200827-5055 FERC PDF (Unofficial) 8/26/2020 8:01:26 PM
Tuolumne Model Review ES-3 August 2020
incorporate model features to make it easier to evaluate customized water management scenarios such as a user-friendly interface like Shiny (an R package for developing interactive web applications).
We found the Chinook salmon population model to be a useful tool for evaluating the production of emigrant Chinook salmon smolts in the Tuolumne River in relation to habitat conditions, including flow regimes and predation effects. The model can provide important insights to scientists and managers alike about the status of the population and factors affecting population p erformance.
More specifically, we found that it appears to have utility to help diagnose the effects of various conditions threatening population performance and identify and evaluate management actions that can improve performance. That said, there are se veral areas in which the model can be improved. In addition, reports prepared by the Districts and their consultants do not clearly present all the results from the model. Below, we summarize a few important findings and issues we identified during our review of the Chinook salmon population model (more detailed comments are provided in the body of the report).
• We conclude that the model indicates that the Chinook salmon population is most threatened by extremely low intrinsic productivity. This means that the population is being most adversely affected by habitat quality (not quantity), which would include the effects of predator populations. According to the model, a shortage of habitat quantity, including spawning habitat and gravel availability, is not a limitation on the population at abundance levels that are of concern. Thus, gravel augmentation would not significantly i mprove population performance. Similarly, increasing flow during spawning to increase available spawning habitat would likely have on ly small or negligible effects on the population. • The model, as configured, indicates that the status of the Chinook salmon population is extremely precarious and bold actions will be needed to prevent extirpation. This need, according to the model, would best be met by very substantial increases in flow releases during spring (the period of active smolt outmigration from the river). The model suggests that management actions with the most certainty in providing real benefits would involve increases in flows during smolt outmigration. Other actions would be expected to provide relatively low benefits compared to spring flow increases. These include reductions in predation rates (unless those reductions could be of a significant magnitude) and increases in spawning habitat through gravel augmentation (even if those increases were large ). • The model is not a full life cycle, which hampers its utility for evaluating potential benefits of management actions to the overall population. The model also does not accoun t for population components that contribute to overall adult production other than fish that smolt while in the river. Fry migrants (newly emerged fry), slightly older fry emigrants, juvenile s that emigrant prior to smolting, a nd juveniles that residualize and continue to rear in the river are treated as mortalities in terms of their contribution to population productivity. In this regard , 20200827-5055 FERC PDF (Unofficial) 8/26/2020 8:01:26 PM
Tuolumne Model Review ES-4 August 2020
the model has a very narrow scope that omits important life histories that are known to contribute to the population based on analysis of otoliths. While the model can be used to inform relative differences between management alternatives wit hout including these life history expressions, the assessment will be inco mplete without considering how the entire population responds to the actions. Thus, in our view, the model falls short of meeting the guidance provided by FERC on model development. Because it is not a full life-cycle model, the Chinook salmon population model as configured is inadequate for managing the Chinook salmon population for conservation or fisheries over the term of a FERC license because it does not inform surplus over repl acement, as discussed in the body of this report. It is an in- river smolt production model that estimates the smolt production resulting from a pre -set number of spawners .
• Uncertainties exist with the model, particularly with regard to parameters related t o predation effects. Estimates of mortality during the smolt-to-smolt life stage based on the rotary screw trap (RST) studies are the largest driver of the results produced from the model. Smolt-to- smolt mortality refers to the loss of fish in the river fr om the point of attaining smolt status to the point of leaving the river a s an emigrant. We found the model did not calibrate well to observed smolts arriving at the Waterford RST, which brings into question its ability to estimate life-stage transitions and survival to this sampling location. The relationship between flow and survival based on the RST data can take several forms, all of which appeared to incorporate a high degree of variability in the data at certain flow levels. We believe there is a need to improve the estimates of smolt-to-smolt survival if the model is to be used for evaluating management alternatives, or at the very least , to improve the confidence in the estimates and the relationships between survival and flow developed based on the estimates. • The volume of water available for fish conservation and fisheri es management is limited.
Given this, stakeholders should use the model to explore tradeoffs among 1 ) winter flow augmentation to displace fry downstream (knowing that displaced fry in the model do not contribute to smolt-to-smolt survival but some do return as adults); 2) winter flow augmentation for rearing (early rearing flows during March and possibly February have been found to be particularly important factors controlling adult recruitment in the San Joaquin River Basin); 3) spring pulse flows during April and May as proposed by the Districts; and 4) the value of fall pulse flows for adult attraction.
• We estimated the number of adult recruits that would be produced from the model ed estimates of smolt emigrants leaving the Tuolumne River, and usi ng an optimistic average smolt-to-adult recruit survival (SAR) of 5% for illustration, the estimated intrinsic productivity of Chinook salmon is 0.14, which is well below the spawner replac ement level of 1. Therefore, if all assumptions in the Chinook salm on population model are correct, the model suggests that the population has already been extirpated or will be soon. The situation is likely worse 20200827-5055 FERC PDF (Unofficial) 8/26/2020 8:01:26 PM
Tuolumne Model Review ES-5 August 2020
than indicated by the model because harvest is not incorporated into the model nor is the effect of hatchery strays on reproductive success, and because an assumed SAR of 5% is unrealistically high.
• It is quite likely that predation is the reason for the apparent poor smolt-to-smolt survival.
Therefore, it is reasonable to try and reduce predation effects during the smolt migration period. While predation effects are estimated to be large, the Chinook salmon production model cannot identify the number of predators that would need to be removed or h ow much of a reduction in consumption would be required to achieve a significant increase in smolt-to- smolt survival. The response from predator control is assumed, not predicted. In contrast, the model predicts, and does not assume, changes in smolt-to-smolt survival associated with flow. That is, the model demonstrates a clear and positive relationship between mean April flows and smolt-to-smolt survival in the Tuolumne River. • A modeling report needs to be prepared that provides greater clarity and trans parency for how the model is structured and operated with clear and concise instructions for application.
Modeling results need to be presented in a manner that provides clear guidance on interpreting model outputs for application to management. These aspe cts should be developed in collaboration with stakeholders and pote ntial users.
O. mykiss Population Model
The O. mykiss population model is a complex, spatially explicit, individual-based model . It uses an individual-based framework to represent the majo r life history processes affecting O. mykiss maturation, spawning, egg incubation, juvenile growth, movement, mortality, and anadromy rates to estimate juvenile and smolt production and end -of-year age-2 and older fish (assumed to reflect adult abundance) as a function of varying flows and water temperatures in the lower Tuolumne River.
As with the Chinook salmon population model, the O. mykiss population model is not us able by most stakeholders. In addition, the O. mykiss modeling report is confusing and d ifficult to follow given the complexity of the model. It took us a large amount of time to become competent enough to run and understand the model. It is not user -friendly, which means that few will be able to run and understand the model results. This is unfortunate in that regulatory agencies probably cannot use the model to evaluate various management strategies. As with the Chinook salmon population model, a user-friendly interface is needed to make the model more usef ul to all stakeholders for modeling scenarios other than those packaged with the model.
Unlike the Chinook salmon population model, after our review and analysis of the O. mykiss population model, we conclude that the O. mykiss population model is not useful at this time.
Although it is evident that the investigators did a large amount of work in developing the model, we found that the structure and conceptual underpinnings of the O. mykiss population model are not well supported for this species in the Tuo lumne River. Because of very limited data for O. mykiss in 20200827-5055 FERC PDF (Unofficial) 8/26/2020 8:01:26 PM
Tuolumne Model Review ES-6 August 2020
the river, and particularly with regard to the possibilities for anadromy, and the obvious adaptation of the model from the Chinook salmon model including its parameterization, the O. mykiss model seems contrived with questionable utility. Perhaps most confusing to us is the use of a combination of a part of the steelhead life history together with a resident population, which also does not incorporate a full life cycle. The outputs from this mixtur e are difficult to interpret and ap ply. Below, we summarize a few important concerns we have with the O. mykiss population model (more detailed comments are provided in the body of the report). • The O. mykiss population model should not be used for diagnosing or evaluating management actions related to the anadromous form of this species, given the model’s current structure, its parameterization, and its calibration and validation. • The model attempts to combine an artificial and unrealistic number of steelhead spawners with two different levels of resident fish spawners in a manner that is unnatural, not transparent, and difficult to follow in both the model and the model documentation. The conceptual underpinnings of doing this in the model are not well supported. We found several significant inconsistencies between the original and updated modeling results that are difficult to understand, which raised further concerns to us about the reliability of the model. • The model is structured and parameterized based on concepts and parameter settings used in the Chinook salmon model. The life histories and behaviors of these two species are dramatically different. A model structured to accommodate juvenile Chinook salmo n is inappropriate to address the needs for O. mykiss modeling, especially for the a nadromous form. Movement patterns of fry and juveniles of ocean -type Chinook salmon are much different than those of juvenile O. mykiss, whether in the anadromous or reside nt form.
Models developed to assess responses of these two species to freshwater env ironmental factors, therefore, need to account for differences in life history patterns between the species in how each individual model is structured and parameterized. • A key assumption in the O. mykiss model is that predation by predatory fishes is a maj or cause of poor performance of O. mykiss, and presumably to the production of the anadromous form of the species. Three parameters within the model were informed by the results of the RST data as it was used to estimate smolt-to-smolt survival of Chinook salmon.
However, there is no evidence that predation on O. mykiss is comparable to or similar in any way to that of juvenile Chinook salmon. In fact, as far as we can tell, there is no evidence of predation on juvenile O. mykiss by predatory fishes in the Tuolumne River. • Because of limited amounts of information available for O. mykiss in the river, the model cannot be adequately calibrated or validated. The authors of the O. mykiss modeling report recognized this limitation. They stated: “In the absence of reliable information on the numbers and timing of any anadromous O. mykiss spawning and the factors contributing to anadromy in the Tuolumne River, the relative changes in the production of O. mykiss smolts resulting 20200827-5055 FERC PDF (Unofficial) 8/26/2020 8:01:26 PM
Tuolumne Model Review ES-7 August 2020
from different flow and temperature co nditions within the Tuolumne River cannot be reliably assessed using the TROm model.” We agree with this assessment. • We found that the factors affecting anadromy of O. mykiss in the Tuolumne River were not adequately addressed. It would be more useful to a pply a framework like the one described by Satterthwaite et al. (2009, 2010) to O. mykiss in the Tuolumne River to examine potential anadromy because it is the anadromous f orm of the species that is listed under ESA, not the resident form.
Despite these shortcomings, it bears noting that the model, as developed, found water temperatures to be the major environmental factor driving juvenile O. mykiss productivity downstream of the dam.
Flows released below La Grange Dam are apparently the maj or factor affecting water temperatures.
Recommendations
We concluded that the Chinook salmon population model is useful but not us able by all stakeholders and the O. mykiss population model is neither useful nor us able. From our perspective, solutions exist for the issues we raised with the models. Based on our review and analyses of the population models, we offer the recommendations listed below to gather additional information and conduct additional analyses to increase confidence with the models, characterize scientific uncertainty, and address key aspects of managing the river over the term of the FERC license that are missing from the current analytical framework. For the O. mykiss population model, we offer a suggested path forward focused on understanding how to stimulate anadromy and what that implies in terms of water management and project operations. However, from our perspective, even if the O. mykiss model in its present configuration could be improved to address the shortcomings we identified, it is a rainbow trout model that is not useful to NOAA Fisheries as a steelhead recovery tool.
Implementing these recommendations will improve the understanding of key relationships between the species modeled and their environment and analyses of alternatives designed to improve salmonid productivity in the lower Tuolumne River.
• For both species:
ࢼ Develop an analytical framework that will allow an evaluation of both target species at the same time. Currently, each species is addressed separat ely. We found no discussion of optimizing management alternatives for both species at the same time or identify ing tradeoffs between species and alternatives. A key attribute of quantitative models is that they support these types of analyses and discussio ns. ࢼ Incorporate climate change into the modeling framework for both species to assess the potential effects changes in hydrology and water temperatures will have on river management alternatives and salmon and steelhead populations over the course of the FERC license.
20200827-5055 FERC PDF (Unofficial) 8/26/2020 8:01:26 PM
Tuolumne Model Review ES-8 August 2020
• For Chinook salmon:
ࢼ Characterize the variability in modeled flow -to-survival relationships to inform the sensitivity of model outputs to key relationships and data points incorporated into the model. Estimating uncertainty is a critical element of communicating model result s. ࢼ Conduct additional analysis of Tuolumne River RST data because it appears that multiple factors associated with fry and smolt catch are interacting (e.g., absolute catch, flow, and rearing and behavior). These factors influence estimated catch and survi val between RSTs, and thus the number of smolts estimated to be emigrating from the Tuolumne River. The influence of these factors on the magnitude and variability of smolt production should to be addressed in an analytical f ramework, including the influence and sensitivity of RST catch during periods of ascending flow that were not incorporated into the Chinook salmon smolt flow -to-survival relationship used in the population model.
ࢼ Estimate survival using mark -recapture methods that incorporate estimated detection probability into survival estimates to independently validate RST -based estimates and inform flow-to-survival relationships. Conduct the studies over multiple years and under all major flow conditions (water year types) and within each year and a cross reaches .
This is needed to develop a better understanding of how survival varies with multiple environmental factors and location.
ࢼ Incorporate the effects of hatchery strays on the overall productivity of the populatio n into the Chinook salmon model . Based on our analysis, Chinook salmon in the Tuolumne River may already be close to being extirpated —the population appears to be precarious at best. The effects of hatchery strays on the overall productivity of the population were not incorporated into the Chinook salmon population model. This needs to be included to inform whether river management alternatives can reduce the negative impact of strays on the natural population and increase population productivity.
ࢼ Conduct additional Chinook salmon otolith analyses to quantify stray rates, reconstruct the in-river conditions conducive to juvenile survival and adult escapement, and inform water management alternatives.
ࢼ Conduct a detailed study of parentage from deoxyribonucleic acid (DNA) to help inform the effects of redd superimposition on Chinook salmon egg -to-fry survival. • For O. mykiss:
ࢼ Model growth as a function of environmental conditions and use sensitivity analyses to predict likely evolutionary endpoints to assess how best to express anadromy in the Tuolumne River and what that implies in terms of water management and project operations. With that information in hand, implications and tradeoffs between 20200827-5055 FERC PDF (Unofficial) 8/26/2020 8:01:26 PM
Tuolumne Model Review ES-9 August 2020
management goals for Chinook salmon and steelhead and recovery goals for steelhead can be discussed and decisions made on the best operations and water management scenarios for both species.
ࢼ Consider recruitment from “outside” sources in the model because the influence of increased flow effects in the lower Tuol umne River cannot be separated from effe cts on estimated population size due to recruitment from above La Grange Dam in high -flow years such as 2011.
ࢼ Conduct a detailed study of parentage from DNA to help inform the effects of redd superimposition on O. mykiss egg-to-fry survival.
Acknowledgements
Finally, we want to acknowledge the tremendous amount of work and effort conducted by the Districts, their consultants, and the stakeholders to gather the information needed to parameterize and develop the models . Although we found faults with both popu lation models and concluded that the O. mykiss population model is not currently useful, we believe the invest igators did their best to develop models with the available information. We also thank NOAA Fisheries for giving us the opportunity to review the models. We hope the Districts and stakeholders find our independent review helpful and constructive.
20200827-5055 FERC PDF (Unofficial) 8/26/2020 8:01:26 PM
Back Room Bay-Delta Voluntary Agreement Scheme is Inequitable , Exclusionary, Inadequate and Lacks a Scientific Foundation
On March 29, 2022, a group of water districts, state agencies, and the Bureau of Reclamation released a memorandum of understanding (MOU) to reach a Bay-Delta “voluntary agreement” (VA). The VA scheme is intended to replace existing standards and circumvent efforts by the State Water Resources Control Board (State Board) to increase protections for the Bay-Delta and Central Valley rivers, and strengthen other environmental requirements in the Board’s Bay- Delta Water Quality Control Plan. The Bay-Delta is in crisis, as demonstrated by the risk of multiple fish extinctions, declining economically valuable salmon runs, harm to tribal lifeways, the explosive growth of harmful algae blooms in the Delta and more.
The VA proposal is incomplete, unenforceable, inequitable, inadequate, and lacks a scientific foundation. The process has excluded most of the parties affected by declining Bay-Delta conditions. It is not a scientifically credible effort to respond to the crisis in the vast Bay- Delta ecosystem or California’s long history of inequitable water policies. After more than a decade of water district promises of a Bay-Delta agreement, it is clear that the VA process has failed. It now represents little more than an attempt to delay action by the State Board to improve conditions in the Bay-Delta and Central Valley Rivers. It is time for the State Board to finish updating, and to implement, the Bay-Delta Water Quality Control Plan. The many flaws in the VA process are described in more detail below.
Inequity in Both Process and Substance: To call the March VA MOU a breakthrough on Bay- Delta issues is absurd. The secret negotiations that led to this VA proposal excluded many critical stakeholders, including tribal, environmental justice, environmental, and fishing interests. It also excluded Delta communities. These groups represent those hit the hardest by inadequate environmental protection requirements. In fact, the current document is not supported by any environmental, environmental justice, fishing, or tribal advocacy group or
tribe, located in the Bay-Delta watershed. The VA scheme represents a power grab by a small group of privileged water interests that chose to exclude the perspectives of others.
The VA approach doubles down on California’s inequitable water rights system, which is based on a long history of discrimination, genocide, and a disregard for environmental health. For example, the outline entirely excludes issues that are of critical concern to environmental justice and tribal interests, such as temperature protections for salmon runs and action to reduce harmful algae blooms.
Inadequate Proposed Water Flows, Exacerbated by Adoption of the Trump Biological Opinions as a Foundation: At the heart of the VA proposal is an entirely inadequate proposal for freshwater flows to protect ecosystem health, disadvantaged communities, commercial and recreational fishing, and tribal values. The scheme would provide inadequate water to protect the environment in all year types. This problem is most obvious in dry years in which the ecosystem suffers the greatest damage. In the driest years, the MOU proposes far less water for the Bay-Delta and Central Valley rivers than was required in 2018, before the Trump Administration gutted ESA protections. In these years, the outline represents a step backward.
The graphic below, prepared by San Francisco Baykeeper compares multiple VA proposals using a single baseline to allow an “apples to apples” comparison. It shows the proposed rollback in critically dry year protections and reveals that the VA scheme would provide a small fraction of the water for the environment that the State Board proposed in its 2018 Framework. It also shows that the current VA proposal is far worse than two previous VA frameworks.
The 2022 VA MOU adopts the Trump Bay-Delta ESA Biological Opinions (BOs) as the “baseline” - the foundation for this agreement. This was not the case in the February 2020 VA outline. This decision dramatically reduces protections for the environment, as shown in the graphic above.
Paradoxically, the State of California has successfully sued to overturn the Trump BOs and federal agencies have begun the process of replacing these science-free operating rules.
Interfering with New, Science-Based Federal Biological Opinions: One VA signatory, the Westlands Water District (WWD), is already using the VA MOU as leverage to block new science-based Bay-Delta ESA BOs. At an April 22 Westlands board meeting, WWD General Manager Tom Birmingham stated that:
“The operations that are assumed in the voluntary agreements include the operational flexibility incorporated into the 2019 biological opinions…..So again, if the wheels come off the bus and the new biological opinions look dramatically different, there won’t be a voluntary agreement.”
It is important to note that Trump Bay-Delta BOs were written while David Bernhardt, a former lobbyist for Westlands, was in charge of federal water policy in California.
Endless State Board Delays: The state and water districts claim that a VA will lead to rapid updating and implementation of antiquated 1995 Bay-Delta water quality standards. But the effort to reach a negotiated agreement is more than 10 years old. Similar VA outlines were released in February of 2020 and December of 2018. Despite this decade of secret meetings, the recent agreement to reach a VA is incomplete, non-binding, and fatally flawed. Many of the water districts that would need to contribute to the final VA have not signed the MOU.
Smoke and Mirrors – Not New Water, Habitat, or Funds: The VA framework inaccurately counts existing ecosystem water and funding for habitat restoration as “new” contributions.
For example, it counts existing state funds and CVPIA Restoration Fund dollars as contributions of this negotiated agreement. In fact, restoration activity from these existing funds will continue with or without a Bay-Delta VA. Further, the outline counts as VA contributions the environmental water anticipated from storage projects under consideration by the California Water Commission. Again, these projects were underway well before the VA MOU was developed and are unrelated to it.
No Biologically-Based Targets: The framework includes no meaningful biological targets to measure success or failure. In fact, the outline would delay the State’s existing salmon doubling requirement until 2050 – long after this agreement would terminate. Without biologically- based metrics, adaptive management would be impossible, leading to the risk that the program could be declared a success even if the ecosystem and species continue to stagnate.
Failure to Learn from Past Experience: The VA relies on voluntary purchases of environmental water and proposes to manage that “block of water” to deliver environmental benefits.
However, the VA process has not incorporated lessons from similar past efforts. For example:
• The Central Valley Project Improvement Act’s Level 4 refuge water supply program has not yet purchased legally required water 20 years after the legal deadline. • The 2000 CALFED Environmental Water Account’s block of water cost taxpayers nearly $100 million and failed to deliver environmental benefits. • The VA framework fails to address the many “baseline” and accounting issues that plagued the CVPIA’s 3406(b)(2) environmental block of water.
This failure to learn from past experience, combined with the lack of a credible enforcement program (see discussion below), reveal a major risk that the overall program and the enforcement component could both fail. (See the Defenders of Wildlife Building Blocks paper for a complete discussion of the lessons learned from past block of water programs.)
Undermining Credible Science: The VA proposal does not have a credible scientific foundation.
It ignores high water temperatures resulting from reservoir management practices that kill the majority of salmon eggs. It relies on habitat restoration as a substitute for river flows despite the lack of evidence to support such a trade. Indeed, the state has provided no modeling of the biological outcome of the proposed VA. The state’s analysis of the 2018 VA proposal (which promised more water than the current VA MOU) showed it would fail to protect water quality or fish and wildlife.
In addition, the outline proposes to undermine the ability of regulators to use the best available science by giving water agencies more control. Water districts have referred to this as a “collaborative” approach. However, this approach has already failed in “collaborative science” efforts related to the Bay-Delta BOs. Unfortunately, many VA participants have for years ignored and undermined the wealth of peer reviewed science regarding the need for a large increase in environmental flows. This fox should not be put in charge of the henhouse.
No Enforcement: The VA scheme lacks a credible approach to enforcement, in the event that promised water and habitat restoration fail to materialize, or in the event that the program proves ineffective. In fact, serious evaluation of the program would not begin until year six of the VA’s 8-year life span.
No Post-VA Strategy: The VA MOU does not include a credible proposal for a regulatory strategy to replace the VA promptly in the event that it fails. In fact, the VA proposal would allow this inadequate scheme to be extended by as much as another seven years, beyond the originally 8-year term.
Sept. 1, 2022
September 14, 2020
Commissioner Ann Moller Caen, President
San Francisco Public Utilities Commission
525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94012
RE: Independent Scientific Peer Review of Tuolumne River Fish Models Demonstrates Major Flaws in the Proposed Voluntary Agreement for the Tuolumne River
Dear President Moller Caen and Members of the Commission:
On behalf of the Natural Resources Defense Council, California Sportfishing Protection Alliance, Tuolumne River Conservancy, Restore the Delta, Sierra Club California, Tuolumne River Trust, The Bay Institute, San Francisco Baykeeper, Merced River Conservation Committee, Northern California Council of Fly Fishers International, Golden West Women Flyfishers, Golden State Salmon Association, Central Sierra Environmental Resource Center, Defenders of Wildlife, and the Nature Conservancy, we are writing to provide the San Francisco Public Utilities Commission (“SFPUC”) with a copy of the independent scientific peer review of the fish population models for the Tuolumne River that was recently conducted at the request of the National Marine Fisheries Service. Many of our organizations had requested that SFPUC commit to an independent scientific peer review of these models, which SFPUC staff have publicly claimed justifies their proposed Voluntary Agreement for the Tuolumne River.
The conclusions of the independent scientific peer review performed by Anchor QEA fundamentally undermine the claims of fishery benefits from the proposed Voluntary Agreement. Instead, the peer review demonstrates that significantly increased flows in the Letter to SFPUC regarding Peer Review of Tuolumne River Fish Models September 14, 2020
2 winter and spring months – contrary to the approach of the Voluntary Agreement – are the primary management action that should be taken to prevent the SFPUC and other irrigation districts from extirpating salmon and steelhead from the Tuolumne River.
In particular, the independent scientific peer review by Anchor QEA concluded:
The model, as configured, indicates that the status of the Chinook salmon population is extremely precarious and bold actions will be needed to prevent extirpation. This need, according to the model, would best be met by very substantial increases in flow releases during spring (the period of active smolt outmigration from the river). The model suggests that management actions with the most certainty in providing real benefits would involve increases in flows during smolt outmigration. Other actions would be expected to provide relatively low benefits compared to spring flow increases.
See Peer Review at 3 (emphasis added). Similarly, while staff from the SFPUC and irrigation districts have claimed that the model demonstrates that reducing predators significantly increases returning salmon, the peer reviewers rejected this claim, finding that the model simply assumes that predator control would increase salmon survival:
[T]he Chinook salmon production model cannot identify the number of predators that would need to be removed or how much of a reduction in consumption would be required to achieve a significant increase in smolt-to smolt survival. The response from predator control is assumed, not predicted.
Id. at 5 (emphasis added). Rather than the model demonstrating that predator control would increase survival and abundance of salmon, the model simply assumes that it will be effective.
In contrast, scientists with the National Marine Fisheries Service have recently published a peer reviewed scientific study demonstrating that predator control programs have not been effective in the Bay-Delta in protecting salmon, in which the authors conclude that “the interaction between challenging environmental conditions, rapid predator recolonization, and complex food web dynamics could prevent any feasible top-down localized predator control effort from increasing salmon survival in the Sacramento–San Joaquin Delta.”1 This further undermines this premise of the proposed Voluntary Agreement.
The peer review also concludes that the model demonstrates that gravel augmentation would not benefit Chinook salmon (see page 3). Thus, elements of a Voluntary Agreement that focus
1 See Cyril Michel et al, Limitations of Active Removal to Manage Predatory Fish Populations, N. Amer. J. of Fish.
Mgmt. 40:3-16 (2020), DOI: 10.1002/nafm.10391 (concluding that one time removal of 40-70% of predators in the lower San Joaquin River resulted in no statistically significant effect on salmon survival or predation rates).
Letter to SFPUC regarding Peer Review of Tuolumne River Fish Models September 14, 2020
3 on spawning gravel augmentation are likely to have negligible benefits for the population.
More broadly, another recent scientific study by scientists with the National Marine Fisheries Service and the U.S. Fish and Wildlife Service concludes that rearing habitat restoration is unlikely to benefit Chinook salmon in the absence of significant increases in flow and abundance of salmon,2 demonstrating again that habitat restoration is not a substitute for adequate instream flows.
Finally, the peer review raises additional criticisms of the models. These include:
• Emphasizing that the salmon model solely addresses salmon smolts and fails to analyze effects on other life history strategies like fry and parr. See Peer Review at 3-4. Recent scientific research has demonstrated that multiple life history strategies that provide a diversity in the size of migrating salmon (including parr and fry) are critically important to the overall population of salmon in the tributaries to the San Joaquin River.3 • Identifying significant concerns with the accuracy of the model. See Peer Review at 4. • Rejecting the steelhead model entirely, finding that it is “not useful,” that the structure and conceptual underpinning of the steelhead model “are not well supported,” “seems contrived,” and should not be used for evaluating management actions. See Peer Review at 5-7.
This independent scientific peer review should be a wake-up call for the Commission. The peer reviewers’ criticisms of the models and the model results undermine SFPUC staff’s claims of benefits from the proposed Tuolumne River Voluntary Agreement. Even though the model demonstrates that Tuolumne River flow is the primary determinant of salmon survival and abundance, the proposed Voluntary Agreement would provide far less flow in the Tuolumne River during the critical winter and spring months than the State Water Resources Control Board’s 2018 update to the Bay-Delta Water Quality Control Plan. Indeed, our analysis indicates that under the proposed voluntary agreement, more than 70% of the Tuolumne River’s flow from February to June could be stored or diverted in many years, leaving less than 30% of the flow in the Tuolumne River – and far less in some years.
The independent scientific peer review provides further evidence that the proposed Voluntary Agreement for the Tuolumne River is fundamentally flawed and fails to protect and restore the health of the river and its native salmon, steelhead, and other native species – and the jobs and communities that depend on their health.
2 See Stuart Munch et al, Science for integrative management of a diadromous fish stock: interdependencies of fisheries, flow and habitat restoration, Can. J. Fish. Aquat. Sci. 77: 1487–1504 (2020) dx.doi.org/10.1139/cjfas- 2020-0075.
3 See Anna Sturrock et al, Unnatural selection of salmon life histories in a modified riverscape, Glob Change Biol. 2019;00:1–13.
Letter to SFPUC regarding Peer Review of Tuolumne River Fish Models September 14, 2020
4 We urge the Commission to direct SFPUC staff to withdraw the flawed proposal for a Voluntary Agreement on the Tuolumne River and to cease making any claims of fishery benefits from the proposal, which are based on these flawed models. Instead of focusing on ways to reduce the amount of water flowing in the Tuolumne River, we encourage you to work with us to find ways to support investments in local and regional water supply projects that would create good paying local jobs, improve the resiliency of the water systems, and help sustain the economy with reduced diversions from the Tuolumne River. Across California, many water agencies are far ahead of the SFPUC in making these investments.
Thank you for consideration of our views.
Sincerely,
Doug Obegi Chris Shutes
Natural Resources Defense Council California Sportfishing Protection Alliance
Alison Boucher Barbara Barrigan Parilla
Tuolumne River Conservancy Restore the Delta
Kathryn Phillips Mark Rockwell
Sierra Club California Nor. Cal. Council, Fly Fishers International
Gary Bobker Jon Rosenfield
The Bay Institute San Francisco Baykeeper
Michael Martin, Ph.D. Peter Drekmeier
Merced River Conservation Committee Tuolumne River Trust
Letter to SFPUC regarding Peer Review of Tuolumne River Fish Models September 14, 2020
5 Cindy Charles John McManus
Golden West Women Flyfishers Golden State Salmon Association
Rachel Zwillinger John Buckley
Defenders of Wildlife Central Sierra Environmental Resource Center
Jay Ziegler
Nature Conservancy
ENCLOSURE
From: Peter Drekmeier
To: Commission
Subject: Salmon Count Data Sources
Date: Wednesday, November 9, 2022 9:12:39 AM
Attachments: Screen Shot 2022-11-03 at 2.22.37 PM.png
Tuolumne Salmon Count Comparison.png
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Dear President Ajami and Commissioners:
I’m writing to follow up on my comment at yesterday’s meeting regarding the following slide presented by your staff.
As I pointed out, the data sources in the graph were changed in 2008 from CDFW carcass surveys to Tuolumne weir counts. These two sources count different things. You’ll see from the table below that Tuolumne weir counts average about 2.5 times greater than the carcass surveys. The above slide should be amended to reflect a consistent source.
The appropriate source to use is the CDFW carcass surveys, not only because they go back a lot further in time, but because the Salmon Doubling Goal is based on these numbers.
Please direct staff to compare apples to apples and correct the slide.
Thank you.
-Peter
-----------------------
Peter Drekmeier
Policy Director
Tuolumne River Trust
[email protected]
(415) 882-7252
From: TIm Hutchins
To: Commission
Subject: Fwd: HHWP Releases Notification, 11/10/2022
Date: Saturday, November 19, 2022 2:20:27 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Sent from my iPad
Recent history of fish populations in the lower Tuolumne.
My name is Tim Hutchins and I worked as a fishing guide on the lower Tuolumne reach below La Grange dam from 1999 to 2005.
The flood of 1997 carried trout from above La Grange dam after it was overtopped into the reach below.
Before that the river didn’t have any trout or salmon.
The 9 cubic feet per second that leaked out of La Grange dam was the only water in the river before the 1995 flow agreement was implemented.
The New Years flood of 1997 not only carried fish with it but it moved entrenched gravel, built woody debris piles, restored overgrown floodplains and sorted gravel into riffles.
Within two years there were robust populations of aquatic invertebrates and dense mayfly and caddis fly numbers, a healthy population of cold water trout, and salmon began returning in significant numbers.
Water levels never were below 200cfs for the next 4 years.
The fish thrived, salmon numbers peaked at over 20,000, steelhead, resident trout and even some spring run salmon were in the river.
During that time the river contained large schools of salmon smolts, immature salmon, that were about 7” long.
They would surface feed mixed with the trout.
I often caught and released a dozen day.
Those smolts were almost a year old and still in the river.
Thats how long it takes to obtain that size.
They had over summered in the river and out migration happened during the late winter/ early spring high flows.
They would be gone by late spring, I wouldn’t catch or see them after that.
The out migration occurred during early spring with cold water temperatures when warm water predators were not active.
These smolts were 14 to 16 months old, vigorous and healthy and much better equipped to make it thru the delta.
Currently summer flows don’t support that life history, temperatures are to high for salmon smolts to summer over in the river.
A certain number of salmon do out migrate their first spring after they are spawned in the fall, soon after hatching.
They are of course smaller, and their timing puts them into the delta later, with less outflows, more diversions, higher water temperatures and more active predators.
Not a big shock then that they are not very successfully getting out to saltwater.
I think the current Tuolumne river returning salmon are a mix of wild and hatchery strays.
Very few if any are wild Tuolumne fish are the progeny of fish that spawned in the river.
Most are from the Merced and Mokelumne salmon hatcheries.
After spawning the rearing conditions for these fish are dismal, because of the low flows that affect summer water temperatures.
The districts premise that few fish manage successful outmigration is correct.
Return numbers reflect hatchery release numbers and ocean conditions, not the viability of the Tuolumne to support self sustaining runs.
The districts shift blame for the low salmon return numbers not because of the poor habitat the currently inadequate summer flows provide, but to predation in the river and delta from warm water predators.
Colder flows exclude those predators, and salmon smolts, those with wild genetics and that have spent more months in the river, are both larger and more capable of predator avoidance.
They will be far more successful returning to spawn and in much higher numbers.
The recent history of the recovery of the fish populations post 1997 flood show the potential of the lower Tuolumne.
Keeping enough flow in the river every summer to maintain a functional cold water ecosystem is the obvious solution.
Scheduling baseline flows by dates on a calendar is arbitrary and in no way maintains viable critical habitat.
There is no guarantee that water temperatures will be cool enough when they are most needed.
Flows need to be maintained at whatever level keeps the water at the required temperature for salmonids to summer over in the river.
Not by what the date is on the calendar.
Climate change has made any non-temperature based summer flow decisions as management for extinction for Tuolumne salmonids.
Fishing guides get no credibility, but my income depended on successfully outings.
That requires being a very engaged observer, understanding aquatic habitat and fish behavior.
Just the total number of hours/ days I spent on the water exceeded the level of any of the fisheries managers.
My lack of credibility has been summarized as “ incidental reports from a local fishing guide”, by FishBio employees working for the districts.
Well the current incidental fishing guide reports is that inadequate low flows result in warm temperatures that have reduced the resident cold water fish populations to zero.
The solution is obvious with a proven track record.
More cold water.
Thanks
Tim Hutchins
Sent from my iPad
Begin forwarded message:
Sent from my iPhone
Begin forwarded message:
From: "Walters, Reggie D"
<[email protected]>
Date: November 9, 2022 at 2:26:11 PM PST
To: "Graham, Chris"
<[email protected]>, "Waelty,
Nicholas" <[email protected]>,
"Forrester, Harrison"
<[email protected]>, "Chen,
Hanbing" <[email protected]>
Subject: HHWP Releases Notification,
11/10/2022
Good afternoon,
A brief update on projected Tuolumne River
flows below HHWP facilities is being provided
after a resumption in powerdraft releases at
Holm Powerhouse.
Cherry Reservoir
Valve releases are at approx. 6cfs.
Beginning Thursday, November 10, Holm
Powerhouse will cycle up and down
daily, with higher flows (approx. 300-500
cfs) expected during the 4pm-9pm
period, and lower flows (approx. 50 cfs)
otherwise.
Lake Eleanor
Valve releases are at approx. 6 cfs.
Hetch Hetchy Reservoir
Valve releases are at approx. 50 cfs
through November 30, reducing to 40
cfs on December 1.
No spill is expected from Kirkwood until
next Spring, unless weather patterns
shift dramatically.
Thanks,
Reggie Walters
Water Operations Analyst | Hetch Hetchy Water and
Power
San Francisco Public Utilities Commission
PO Box 160, Moccasin CA 95347
209.989.2809
[email protected]
OUR MISSION: To provide our customers with high-quality, efficient and reliable water, power and sewer services in a manner that values environmental and community interests and sustains the resources entrusted to our care.
525 Golden Gate Avenue, 13th Floor
San Francisco, CA 94102
T 415.554.3155
F 415.554.3161
TTY 415.554.3488
San Francisco Public Utilities Commission
Correspondence Log
Invest in Solutions to Prevent Harmful Algae Blooms & Fish Kills November 11, 2022 through November 26, 2022
Date Received From City
November 11, 2022 Nicole Hoppe Lafayette
November 12, 2022 Andrea Horbinski Kensington
November 13, 2022 Brenna Moorehead San Francisco
November 15, 2022 Adrian Cotter Oakland
November 20, 2022 Robert Crabill San Anselmo
November 22, 2022 Margaret Mischner San Francisco
November 26, 2022 Antony Tolstunov San Francisco
From: [email protected] on behalf of Nicole via San Francisco Baykeeper To: Commission
Subject: Please Invest in Solutions to Prevent Harmful Algae Blooms & Fish Kills Date: Friday, November 11, 2022 7:06:05 AM
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To: Mayor London Breed
CC: SFPUC General Manager Dennis Herrera, SFPUC Commission, and the San Francisco Board of Supervisors
Dear Mayor Breed,
I urge you to direct San Francisco’s Public Utilities Commission (SFPUC) to aggressively increase the city’s investment in water recycling today.
This summer, a large harmful algal bloom has spread across the Bay, leaving unimaginable numbers of dead fish in its wake. We’re still learning about this particular bloom, but what we do know is that San Francisco’s sewage effluent contributes to excessive levels of nutrients in San Francisco Bay that make the Bay fertile territory for the spread of harmful algae blooms.
Water recycling and other wastewater management technologies can help by reducing the volume of polluted discharges into the Bay. In addition, by producing potable supplies, water recycling will reduce San Francisco’s reliance on water diverted from the Tuolumne River, increasing the city’s resilience to climate change effects on water supply.
Other cities have learned the lessons of California’s unpredictable climate and are quickly adopting water recycling to reduce their burden on the ecosystem, while increasing the reliability of their supply. Orange County gets more than 75 percent of its water through its water reuse program. Las Vegas recycles nearly all of its water used indoors. And Los Angeles is on the path to reusing 100 percent of its wastewater by 2035.
But, as San Francisco’s draft Urban Water Management Plan recently revealed, the city
currently has no plans to make recycled water widely
available in the next 25 years. Instead, the city is pursuing multiple expensive and misguided lawsuits so that it can continue to rely, almost exclusively, on the Tuolumne River—one of the state’s most overtapped rivers—for the next several decades. San Francisco and large agribusiness water districts divert four out of every five gallons of water that flow in the Tuolumne River during a typical year.
This overuse has caused the river’s once mighty Chinook Salmon populations to crash. Meanwhile, low freshwater flows contribute to deteriorating water quality—including harmful algae blooms—in the Delta and San Francisco Bay.
I agree with Supervisor Aaron Peskin that “it is time for San Francisco and our sister cities in the nine Bay Area counties to start looking at what kinds of infrastructure investments will need to be made as this becomes, sadly, the new normal.” It’s unacceptable for the city with the nation’s greenest reputation to shirk its responsibilities to conserve California’s precious and unpredictable water supply.
I support increasing river flows to protect San Francisco Bay’s fisheries, water quality, and recreation. The city should do its part to protect the Bay and its rivers—water recycling is a common-sense way to limit the city’s water use, increase the reliability of its supply, and protect the Bay from harmful wastewater treatment plant effluent.
Thank you,
Nicole Hoppe
Lafayette, California