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Federal agency concerned state in pushing to take more water from Stanislaus for fish is ignoring scientific research

The federal Environmental Protection Agency is pushing for State Water Resources Control Board to revisit its plan to increase unimpaired flows on the Stanislaus, Tuolumne, and Merced rivers for the purpose of increasing the population of the endangered Chinook salmon.

In a letter sent Oct. 31 from EPA Acting Administrator Andrew Wheeler to the chair of the state water board, the agency points to extensive scientific studies that indicate the Bay-Delta Plan may not achieve the board’s fish population goals.

“These  analyses also suggest  that native fisheries  in the lower San Joaquin  River, its tributaries  and the California Bay-Delta experience  numerous  stressors  including  predation, temperature, interactions with hatchery  fish, lack of spawning and rearing  habitat, ocean conditions, pollutants and other  issues related  to the food  web,” Wheeler wrote. “Although  the EPA has not evaluated  these studies  in detail,  the agency believes  that the studies warrant  careful  consideration by the board.  What degree  of confidence does the  board  have  regarding  the extent  to which  the proposed  unimpaired   flow  objectives,  if implemented fully, will improve  the status of native fish species and reduce mortality  mechanisms notwithstanding the other stressors identified  in these recent scientific studies?”

The bottom line: The EPA, noting the significant federal interests that are potentially affected by the state’s proposal, wants the research considered as well as federal Department of Interior concerns before the state takes final action on the Bay Delta plan even though the comment period has closed.

The EPA letter follows a concerted effort by Congressman Jeff Denham to get federal agencies that are a major player in California water issues given they operate the Central Valley Project that includes the New Melones Reservoir on the Stanislaus River.


“I’m pulling every available resource to stop the state’s dangerous water grab,” Denham said. “Both the Department of Interior and EPA have now directly weighed in against Sacramento’s plan to steal our water.”

At Denham’s request Bureau of Reclamation Commissioner Brenda Burman submitted a letter to the state July 27 expressing serious legal concerns with the Bay-Delta plan. That followed a visit to the region at Denham’s request of Department of Interior Secretary Ryan Zinke to tour impacted reservoirs. After that meeting Zinke sent an internal memo to Interior agencies on Aug. 17 requesting them to oppose the state plan.

Wheeler also wants the state to address Department of Interior concerns regarding the scientific basis of the state’s proposal.

“On behalf of the South San Joaquin Irrigation District, I would like to thank you and your staff for bringing Acting EPA Administrator Andrew Wheeler to our region on October 11, 2018,” SSJID General Manager Peter Rietkerk stated in  a letter to Denham. “The meeting was a success, and our message was clearly heard, evidenced by today’s letter from the EPA to the State Water Board. We’ve continued to lament the devastating impacts of State’s plan to local drinking and irrigation water supplies, and to protected fish species within our rivers, and it is great to know that the EPA has listened and will be looking for balance and accountability from the State Water Board if they choose to approve this outrageous plan.”

The SSJID and OID presented the scientific research data during the state during the comment period but the state chose to dismiss it.


The SSJID-OID research

The stakes of the research financed by the SSJID and Oakdale Irrigation District are high. And they aren’t just limited to the Stanislaus River watershed. Research being conducted by the highly regarded FISHBIO firm with a worldwide reputation for fishery restoration that’s being funded by the two districts to the tune of $1 million a year will also benefit the future of the Tuolumne and Merced watersheds.

The stakes include:

*The future survival of Chinook salmon and steelhead fish.

*The potential of not being able to farm 132,000 acres now irrigated in the Northern San Joaquin Valley.

*120,000 acre feet of water SSJID and OID customers including the cities of Manteca, Tracy, and Lathrop could forfeit in a normal year with significantly larger cutbacks during drought years.

*Increased groundwater pumping of 1.57 million acre feet of water annually by cities and farmers.

*An annual economic loss of $12.9 billion to the combined economy of San Joaquin, Stanislaus, and Merced counties.

*Some $10 million OID and SSJID would lose annually from hydroelectric generation.

*The loss of 4,000 jobs in the region.

*Based on historic hydrology on the Stanislaus River Basin, New Melones Reservoir — the state’s fourth largest at 2.4 million acre feet of water — could go dry 12 times every 95 years.

All of that is based on a state plan announced on Sept. 15, 2016 to commander more than 300,000 acre feet of water from the three rivers in a bid to boost salmon/steelhead population by what state experts project would be a net gain of 1,103 fish combined on the Stanislaus, Merced, and Tuolumne.

The data collected over a number of years suggests the state’s plan to simply throw more water at the problem of native fish survivability is the not the most effective way to go about making gains to protect fish.  

Research points to non-native predators and other issues that are a bigger factor than increased water releases the state is suggesting.

The SSJID-OID goal for more than two decades has been to use science to best help the fish population. That likely means restoration of more spawning areas such as OID’s project at Honolulu Bar as well as addressed predation on the Stanislaus River.

FISHBIO — at the request of OID and SSJID that has continuously picked up the tab — started research and monitoring on the Stanislaus River in 1993.

The ongoing FISHBIO studies show water temperatures and other issues are proving to be more critical and effective that just flushing the river with more water in the early part of the year as the state plan calls for.

It is the most comprehensive and longest running salmon and steelhead monitoring program in the Lower San Joaquin River Basin. The ongoing monitoring activities track the abundance, distribution, migration characteristics, and habitat use of salmon and steelhead trout. The project also seeks to determine the effects of reservoir operations and the highly altered channel geometry —  gravel extraction, levee construction, and woody debris removal — on the fish and wildlife populations in the Lower Stanislaus River.


To contact Dennis Wyatt, email