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San Francisco releases flawed draft EIR for Calaveras Dam replacement project on Alameda Creek

Impacts to Steelhead Trout and Other Wildlife not Adequately Addressed

by Jeff Miller

October 7, 2009 -- Sunol, CA – The San Francisco Planning Department this week released a flawed draft Environmental Impact Report (EIR) for the San Francisco Public Utilities Commission (SFPUC) project to rebuild the seismically challenged Calaveras Dam in the upper Alameda Creek watershed. The Calaveras Dam project will have significant impacts on the restoration of threatened steelhead trout to Alameda Creek and on habitat for numerous other endangered species. The EIR analysis of impacts on native fish and wildlife is incomplete and the proposed mitigations are inadequate, particularly with respect to fisheries issues.
 
“Although we support rebuilding Calaveras Dam as quickly as possible, at issue is how the rebuilt dam and reservoir will be operated,” said Jeff Miller, Director of the Alameda Creek Alliance. “Along with upgrading the aging water supply infrastructure, San Francisco’s water agency needs to be brought into the twenty-first century regarding compliance with modern environmental protections. San Francisco’s water system can and should be operated in a sustainable manner.”
 
In 2008 the SFPUC approved a Programmatic EIR for the entire Water System Improvement Program, a $4 billion program of retrofits to San Francisco’s aging water system, which includes the Calaveras Dam replacement project, scheduled for completion by 2015. The SFPUC originally refused to consider the impacts of its three dams in the Alameda Creek watershed on steelhead, but has since changed their position. However, the draft project EIR inadequately evaluates steelhead impacts and proposes dam operations and minimum flow releases for fish inconsistent with restoring a sustainable run of steelhead below the dam.
 
“We are extremely disappointed with the draft EIR given the extensive communication and input regulatory agencies and our group have supplied the SFPUC regarding the project,” said Miller. “The proposed flows for steelhead trout are clearly inadequate and the mitigations offered for significant construction impacts on sensitive species are meager and inappropriate. If San Francisco wants to rebuild this dam quickly, they need to do the right thing for the affected ecosystems downstream of the dam and release adequate water for fish.”
 
“The SFPUC should adhere to their own watershed stewardship policy, comply with state and federal environmental laws, and leave enough water in the creek so that native fish and wildlife can thrive,” said Miller. “The failure to provide reasonable flows below the dams and controversial proposals to divert even more water from Alameda Creek could unnecessarily jeopardize the schedule for water system upgrades.”
 
Since steelhead trout in the Bay Area and central coast were listed as threatened under the Endangered Species Act in 1997, numerous organizations and agencies have been pursuing restoration projects to allow migratory fish from the Bay to reach spawning habitat in upper Alameda Creek. Eleven fish passage projects at small and medium barriers in the creek have been completed since 2001 and several more major fish ladder and dam removal projects will be completed by 2012. This will allow anadromous fish access to 20 miles of suitable spawning and rearing habitat in the watershed for the first time in almost half a century.
 
Adult steelhead attempting to migrate upstream have been documented nearly every winter the past decade, blocked by barriers in lower Alameda Creek. The Alameda County Flood Control District and Alameda County Water District are working on a fish ladder project that will allow steelhead to bypass a cement barrier known as the BART weir and an adjacent inflatable water supply dam in the flood control channel, the main barriers to fish migration into Alameda Creek. The agencies are aiming to complete construction by 2010. ACWD recently installed five fish screens on their water diversion structures in lower Alameda Creek and removed a rubber diversion dam this summer. The SFPUC removed two dams from the Niles Canyon reach of Alameda Creek in 2006.
 
The SFPUC will need a federal permit for the Calaveras Dam project and had urged the Army Corps of Engineers to make a determination of “no effect” on steelhead trout and issue a permit without a formal consultation with federal regulators under the Endangered Species Act. In 2008 the National Marine Fisheries Service notified the agencies that formal consultation will be required for the project and rejected the “no impact on steelhead” determination.
 
More than 70 Bay Area conservation and fishing groups have called on the SFPUC to improve its stewardship of the Alameda Creek watershed and restore stream flows in Alameda Creek sufficient to sustain steelhead trout. In 2005 the SFPUC lobbied to eliminate Endangered Species Act protections for resident rainbow trout populations in Alameda Creek. In 2006 the SFPUC adopted a Water Enterprise Environmental Stewardship Policy which states the agency will “operate the…water system in a manner that protects and restores native fish and wildlife downstream of SFPUC dams and water diversions, within SFPUC reservoirs, and on SFPUC watershed lands.”
 
The SFPUC manages 36,800 acres of public land and operates three dams in the upper Alameda Creek watershed. Calaveras Dam, completed in 1925, captures runoff from 100 square miles of the Calaveras Creek and Arroyo Hondo watersheds. The SFPUC diverts 86 percent of the stream flows of the upper watershed and plans to divert almost all winter and spring stream flows from upper Alameda Creek at their Alameda Diversion Dam, which diverts flows from upper Alameda Creek into Calaveras Reservoir. Completion of Calaveras Dam trapped formerly ocean-run steelhead trout above the reservoir and blocked fish migration into the best trout spawning and rearing habitat in the watershed. Because the dam is near an active fault zone and was determined to be vulnerable in a strong earthquake, the Division of Safety of Dams in 2001 restricted reservoir storage level to 40 percent of capacity until the dam is rebuilt.
 
The draft EIR an be viewed at http://www.sfgov.org/site/planning_index.asp?id=80530