CSPA and a coalition of environmental and fishing groups filed extensive comments and recommendations on July 22 in the Federal Energy Regulatory Commission’s relicensing of the Merced River Project on the Merced River. The filing makes recommendations for flows in the lower Merced River, fish passage, gravel augmentation, placement of large wood, stocking of fish with native genetics, and monitoring and consultation. The comments acknowledge agreements with licensee Merced Irrigation District for recreational improvements.
Following the approach of the State Water Resources Control Board, CSPA and allied “Conservation Groups” propose that Merced Irrigation District release to the lower river 60% of the February – June inflow to Lake McClure, the Project’s storage reservoir. The Conservation Groups modify the Board’s approach in drier years, reducing the number of months the percent-of-unimpaired requirement would be applied; in Critically Dry years, minimum flows and an additional “block of water” would replace the percent-of-unimpaired approach to maintain basic flow conditions, preserve reservoir storage, and provide flow pulses to move salmon out of the river. Conservation Groups provide output from the licensee’s water balance model to show that water the proposed approach is sufficient if irrigation diversions from the Merced River are reduced. The filing explains:
“Merced ID and other water purveyors in the San Joaquin River and elsewhere have argued that using a percent-of-unimpaired flow in any year is infeasible because of water shortage and depleted storage (with attendant water temperature impacts) in Critically Dry years and in dry-year sequences. Reduction of baseline diversions to restore balance to the Merced River’s beneficial uses, combined with reasonable off-ramps for flow requirements in Critically Dry years (including dry-year sequences), cuts through this tedious hyperbole.”