Since 2006, one of CSPA’s primary areas of effort has been to reintroduce salmon to historic habitat upstream of major Central Valley dams. Today, Central Valley salmon are confined to the valley floor: 5-10% of their historic habitat. In the face of climate change and inadequate flows due to political pressure, regulatory timidity, and frequent bad management, limiting salmon to the valley floor is a strategy for extinction, widespread extirpation, and/or reduction of salmon to a few boutique tourist attractions.
In a July 22 op-ed in the Sacramento Bee (http://www.sacbee.com/opinion/op-ed/soapbox/article28349512.html#storylink=cpy), Yvon Chouinard and Matt Stoecker criticize the Yuba Salmon Partnership Initiative (YSPI), one of the reintroduction efforts of which CSPA has been part. The YSPI is working to create a program to trap and haul adult spring-run Chinook salmon from the lower Yuba River to the North Yuba River, and to capture juveniles moving down the North Yuba River and transport them downstream to where they can gain access to the ocean. Chouinard and Stoecker say that trap and haul is the “wrong way” to recover salmon in the Yuba River, and suggest that trap and haul should be off the table everywhere. Instead, they recommend removal of Englebright Dam.
Central Valley rim dams are here to stay
Dams on the Sacramento, the Feather, the American, the Mokelumne, the Tuolumne, and other major Central Valley rivers aren’t going away. They are all too tall to put fish ladders on. Right now, wild salmon are struggling and in some cases dying on the valley floor. They are competing with fish from hatcheries; but without those hatcheries, there wouldn’t be enough salmon in California to allow any salmon fishing at all. Fish that spawn in Central Valley rivers are affected by extensive hydraulic infrastructure and by dozens of management decisions affecting water operations in the Delta, in the major rivers, and even in the smaller rivers like Butte Creek, where the largest population of Central Valley spring-run salmon is kept going by weekly and sometimes daily oversight. The whole system is managed. What can and must change is how it is managed. It’s high time that part of the management include getting wild salmon back to historic, higher elevation, cold water habitat.
In the big picture, that means getting fish past about five Central Valley rim dams. While options need to be investigated in each case, the likelihood is that this will be accomplished using trap and haul. For CSPA, the question is not whether trap and haul is morally acceptable or achieves “real recovery,” but whether we can reintroduce salmon upstream of rim dams soon enough and well enough to help save the Central Valley’s wild salmon populations. What’s not morally acceptable is to live with the way things are now.
When is dam removal right?
We should not support trap and haul when dam removal is a necessity or a good option. For instance, trap and haul past four Klamath hydropower dams would leave intact horrible water quality problems, and the power loss of Klamath dam removal is relatively easily mitigated. Chouinard and Stoecker are right when they say that “removing low-value, obsolete dams … quickly brings fish back and eliminates other problems.”
CSPA agrees that dam removal is better and cleaner: when and where the conditions support it. On the other hand, we don’t have time to wait for our sense of order to catch up with the need for trap and haul where the only alternative is continuing exclusion of salmon from their historic habitat.
Is trap and haul right for the Yuba? 1. Overview
The op-ed suggests that “the science is clear” that Englebright is one of those low-value dams that should be removed. We don’t think it’s clear at all. In this case it’s a policy that runs up against a lot of difficult facts, about the watershed generally and Englebright Dam in particular.
Since 2009, CSPA has been in the trenches of regulatory processes on the Yuba, leading advocacy, writing extensive NGO comments, and shaping studies on three hydropower relicensings in the watershed. CSPA helped to instigate, establish and maintain the Yuba Salmon Forum to evaluate reintroduction of salmon to the upper Yuba watershed when FERC refused to order such studies on procedural grounds. In the Yuba Salmon Forum, CSPA showed up at more meetings than any other environmental group, made sure that studies got done, was a watchdog for bias, and insisted on completion and publication of reports. Those reports are worth careful review (see engineering reports at http://www.ycwa.com/yuba-salmon-forum and habitat report here: YSF Habitat Matrices Report 092313).
Is trap and haul right for the Yuba? 2. Englebright Dam and Reservoir
Englebright Dam is not nearly as low-value as Chouinard and Stoecker make it out to be. They say it “provides limited hydropower.” Actually, Englebright Reservoir is an “afterbay” for Yuba County Water Agency’s (YCWA) New Colgate Powerhouse, at 340 megawatts one of the largest peaking hydroelectric powerhouses in California. That powerhouse follows daily load on the electrical grid, one of its main purposes and probably the most important function of hydropower generally. YCWA allows the water level of Englebright Reservoir to fluctuate as its operators make irregular releases through New Colgate Powerhouse to meet electric load; the fluctuating reservoir level allows YCWA to keep the flows in the lower Yuba River downstream of Englebright relatively constant over the course of any given day. That’s important for fish: the lower Yuba is one of the best trout fisheries in the state and provides more naturally spawning salmon than most other rivers. Take away Englebright, and there are new problems: you eliminate New Colgate Powerhouse’s main purpose, you require a new afterbay to be built, or you pulse the lower Yuba River almost every day.
All in all, Englebright Reservoir provides a substantial hydropower benefit that YCWA is prepared to go to the mat to defend.
Englebright Dam was initially built to trap hydraulic mining sediment from the Yuba watershed. Chouinard and Stoecker say the sediment should be removed and remediated, as at the Milltown Dam on Montana’s Clark Fork River. The Yuba Salmon Forum looked into that option. There is nine times more sediment behind Englebright than there was at Milltown. Sediment removal at Milltown was accomplished by rail; that would be much more difficult at Englebright, which is located deep in a canyon and for which existing rail is less conveniently situated. Milltown Reservoir was polluted with arsenic and copper from copper mining, and caused the site to become a superfund site with federal funding to remove sediment. Leaving that sediment in place wasn’t an option. Englebright has legacy mercury in it that is of greatest risk when it is disturbed. Moreover, even if Englebright and all the sediment currently behind were taken out, more legacy mining sediment would continue to find its way into the restored stream channel, past the current dam site and downstream into the lower Yuba River.
It’s true that Englebright Reservoir doesn’t have much reserve volume for flood control, and doesn’t add to water supply. That makes it different than most Central Valley rim dams, which perform both of those functions. These facts made dam removal and dam modification (“notching”) worth a hard look. CSPA’s takeaway from the Salmon Forum is that even though Englebright doesn’t fit into the water supply rim dam category, it doesn’t fit into the low value small hydropower dams like those being removed on Battle Creek either.
Is trap and haul right for the Yuba? 3. Laddering or notching
Regardless of its use, Englebright Dam is 260 feet tall. The tallest functioning fish ladder in the world is about half the height of Englebright. The canyon downstream of Englebright becomes a high velocity chute of water during high flows, making a ladder likely to be destroyed in those high flows. The surface water temperature of Englebright is very warm in June and July, when most Yuba River spring-run salmon reach Daguerre Point Dam, about halfway between Englebright and the confluence of the Yuba and Feather rivers. Fish moving up a ladder at Englebright would have to go from the cold water released from the bottom of Englebright into the warm water on the surface of Englebright. Once they got upstream to the outfall from New Colgate Powerhouse, fish migrating upstream would encounter another thermal barrier: cold water released from the depths of New Bullards Bar Reservoir downstream of much warmer water in the Yuba River downstream of the confluence of the North Yuba and Middle Yuba. Cold water species don’t like moving from cold water to warm water; after a certain degree of temperature difference, they just won’t.
In sum, there are a lot of problems with a fish ladder past Englebright, and that doesn’t even address how the juvenile fish born upstream would get past the dam on their way downstream. This is further documented and discussed in the Yuba Salmon Forum reports.
Is trap and haul right for the Yuba? 4. Middle Yuba and South Yuba habitat
So let’s consider removal. Mentioned above is the enormous amount of sediment behind Englebright, which is generally relatively benign until disturbed, but which would need to be treated as toxic waste once it was removed. The estimate for removing the dam, with sediment the biggest cost, is $1.5 billion (high range cost is $3 billion). Now, CSPA is not averse to asking for big dollars in order to get big benefits: when CSPA sued East Bay MUD in the eighties over Penn Mine, CSPA insisted on a high price tag because cheaping out wouldn’t have solved the water quality disaster that Penn Mine was creating in Camanche Reservoir and the lower Mokelumne River. So let’s see what the differential benefit of $1.5 or $3 billion (or whatever it turned out to be) would be.
Contrary to what Chouinard and Stoecker say in their op-ed, there are not “dozens of miles of habitat for salmon, steelhead, sturgeon, and other native species” in the Middle Yuba and South Yuba rivers, unless you count among those “native species” warm water species such as hardhead, pikeminnow and suckers.
There’s no sturgeon habitat at all: sturgeon cannot get past Daguerre Point Dam at river mile 11.4 on the lower Yuba. Daguerre is a barrier whose fish ladders currently pass salmon, steelhead and trout, but which keep sturgeon and striped bass downstream. If Daguerre were removed, it would allow access for striped bass as well as for sturgeon, and would severely diminish the quality of the trout fishery and probably conditions for salmon and steelhead as well in the river between Daguerre and Englebright. While that is a debate for a different day, the benefit to sturgeon would likely stop at “the Narrows,” a natural high gradient canyon that sturgeon are unlikely to be able to pass.
There is very little tributary habitat in either the South Yuba or Middle Yuba watersheds in which steelhead would be likely to find spawning habitat and cold water for oversummering. In the South Yuba watershed, Poorman Creek may have 6.5 miles of accessible tributary steelhead habitat. In the Middle Yuba watershed, Wolf Creek may have 2.5 miles of accessible tributary steelhead habitat. Depending on operation of dams upstream, there is a small amount of accessible but marginal mainstem habitat in the South Yuba and 5-10 miles of accessible mainstem habitat in the Middle Yuba.
There is between five and ten miles of habitat for spring-run Chinook in the Middle Yuba River upstream of Our House Diversion Dam. The amount varies by year, and is limited primarily by water temperature. It is also affected by flow releases from Nevada Irrigation District’s Jackson Meadows Dam and Milton Diversion Dam; with close to optimal flow releases (we modeled different flow schedules) in wet water years, ten miles is the most you can get. There are good holding pools and there is a decent amount of spawning habitat in the Middle Yuba River. There are also a lot of problems for salmon migrating from the current Englebright Reservoir to get to that habitat, including: outfall of New Colgate Powerhouse, previously discussed; low flows and warm water in most years in the Middle Yuba downstream of Our House Dam; a natural barrier at lower flows near the bottom end of the Middle Yuba; Our House Dam (needs a fish ladder); Lohman Ridge Diversion Tunnel (needs a fish screen); low flows in the Middle Yuba above Our House Dam, with flows dropping below 100 cfs in May in about half of all years.
While the habitat reports from the Yuba Salmon Forum suggest that there is a mile or two of spring-run holding habitat in the South Yuba in wet years, it’s only in two good pools and two marginal pools just downstream of the natural fish barrier, even with significantly augmented flows. The greater likelihood is that the South Yuba would become a trap that lured spring-run salmon up the river in the spring but where summer conditions would cause most to die before spawning in the fall. That begs the question whether one should let salmon run up the South Yuba at all, or whether it would be better to try to keep them out with a weir, recognizing that some people would say that this is also inappropriate interference in natural processes.
So that’s the shape of the habitat in the Middle Yuba and South Yuba.
Is trap and haul right for the Yuba? 5. Lower Yuba River habitat and dam removal
To complete the picture, we also need to consider the potential effects of removing Englebright on the lower Yuba River. In general, CSPA opposes sacrificing existing habitat in order to create new habitat.
Now, the lower Yuba River has problems. One of the two prongs of the YSPI is to try to improve the physical habitat in the lower Yuba River. The existing floodplain generally requires very high flows to achieve inundation at critical times. There is a lack of riparian vegetation and canopy. There is a lot of undesirable rock in the river channel, in part from legacy mining and in part from the construction of Englebright and other facilities. Overall, the survivorship of juvenile salmon and steelhead needs to greatly improve.
Nonetheless, the lower Yuba also has a lot going for it. New Bullards Bar Reservoir is very deep, is managed for high carryover storage, and has limited local demand, so that it reliably provides cold water to the lower Yuba (in this case, a dam helps to create habitat). In part because flows out of New Colgate Powerhouse are regulated by Englebright Reservoir, the lower Yuba between the Englebright and Daguerre is one of the premier trout fisheries in California. There is relatively good aquatic insect production, which benefits in part from the marine-derived nutrients from the salmon that spawn in the lower river every year.
Effects on the lower Yuba of removing Englebright are likely variable and would depend on a series of decisions. But it is safe to say that the lower Yuba’s existing habitat and potential habitat would experience a series of new problems because of the legacy mining effects and because of the continued existence and operation of New Bullards Bar Reservoir and New Colgate Powerhouse.
Is trap and haul right for the Yuba? 6. Habitat in the North Yuba River
Yoshiyama’s seminal study of the history of salmon in California tells us that the North Yuba was the principal spring-run Chinook salmon river in the Yuba watershed. Yoshiyama did not find much documentation of salmon in the Middle Yuba and South Yuba, although it is likely there was some use.
The North Yuba is geologically distinct from the highly granitic Middle Yuba and South Yuba basins. The North Yuba has many more year-round tributaries and has an unimpaired summer base flow that is ten times the unimpaired summer base flow of either of the other forks. In wet water years, the North Yuba has 30 miles of habitat suitable for spring-run Chinook salmon. In the driest years, it has 5-6 miles of holding habitat, with more spawning habitat close by downstream.
In addition, the North Yuba is largely unregulated, and thus is hydrologically independent of human action. On the Middle Yuba and South Yuba, water purveyors and PG&E have a political and economic stake in taking water out of the rivers; the North Yuba does not have these issues.
In short, the North Yuba has the historic habitat, the best natural habitat and the least hydrologically altered riverine environment. The problem is that it is the hardest to get salmon to, due to the presence of the 635-foot-tall New Bullards Bar Dam.
Is trap and haul right for the Yuba? 7. Synthesis
There are many questions one could ask in considering the facts and weighing the options of dam removal or trap and haul in the Yuba River watershed. These might include:
Would we get more fish for a more expensive dam removal project?
Would a dam removal project more reliably improve the fishery than trap and haul?
Which option gets the fish to better habitat?
Do we get a reintroduction program sooner with dam removal?
Do we get a reintroduction program at all if we insist on dam removal or nothing?
What option allows the best use of the lower Yuba River for the benefit of fisheries?
Here’s CSPA’s reasoning right now.
There is no single reason that would make dam removal (or even notching) on the Yuba more compelling than trap and haul. There is no compelling water quality issue. Dam removal or modification wouldn’t get fish to better habitat; more likely, the habitat would be worse.
With dam removal, it’s likely that during many years spring-run Chinook would not get to usable upper watershed habitat at all: they’d arrive too late and the water would be too low to allow migration to pools cold enough to support summer holding. If the Middle Yuba were indeed the better option, trap and haul would be the most reliable way to get them there.
Dam removal would take longer and be much more expensive. It’s less likely to help salmon soon.
Dam removal would likely face political opposition. This would likely come not only from YCWA and from others in Yuba County concerned about flood control, but also from PG&E, Nevada Irrigation District and Placer County Water Agency, all of whom have some stake in the management of the Middle Yuba and South Yuba rivers.
Dam removal would require solution of multiple new problems. These include potential effects of removal on flood control, operation of New Colgate Powerhouse, effects on the existing fisheries and habitat in the lower Yuba River, sediment removal or management, and upstream and downstream passage (fish ladder and screen) at Our House Dam. It would probably be necessary to block fish from entering the South Yuba and from entering the easily accessible three miles of the North Yuba downstream of New Bullards Bar dam, in order to protect them from habitat that would not provide cold water in summer and areas to spawn in the early fall. Fish would need to migrate up the relatively warm lower end of the Middle Yuba River; they would also have to navigate relatively low flows in the Middle Yuba River in many years (including a natural low-flow barrier).
An answer would need to be found for the operation of New Colgate Powerhouse. Would it simply become a huge baseload facility, operating at relatively low levels 24-7? Would it be necessary to construct a new afterbay for New Colgate? This would involve a lot of concrete and expense if it would even be feasible to build an afterbay in the canyon to the side of a restored stream channel. And neither baseload operation nor a new afterbay to the side of the river would solve the problem of water temperature: cold water coming out of the powerhouse with much warmer water coming down the river from upstream.
Is trap and haul right for the Yuba? 8. Precedent
Perhaps unnoticed is the fact that we have already set precedent by having the conversation about how to reintroduce salmon to their historic high elevation habitat in the Yuba River watershed. Up till now, the question has not been how to reintroduce fish upstream of Central Valley rim dams, but whether to do it at all.
For the first time, the California Department of Fish and Wildlife has publicly and unequivocally stated that reintroduction upstream of rim dams is not only necessary, but urgent. That is not the conversation we were having with DFW five years ago, when the policy on rivers with rim dams was strictly focused on existing accessible habitat.
Also for the first time, a water agency has unequivocally supported reintroduction upstream of a rim dam and has put real money behind it.
CSPA and others have been advocating for both of these changes for over a decade. Neither in itself has put fish in the water. But both changes have eliminated major policy barriers that in the past made discussion of getting past physical barriers almost impossible. Let’s not lose sight of how important that is.
There are other questions one should ask in considering the facts and weighing the options of dam removal or trap and haul on the Yuba River, in terms of the precedent it would set. Simply put, these include:
What would each option mean for reintroduction in California?
What would each option mean nationwide?
Let’s start with California and consider whether a trap and haul program on the Yuba River would increase the chance that dams in California that should be removed won’t be removed. There are several dams already slated for removal on small hydropower projects in northern California, on Battle and Cow creeks, for example. Will dam owners opt not to remove them because of trap and haul plans or actions on the Yuba? We don’t see it. Will advocates (including CSPA) embrace trap and haul where the facts support removal? We don’t see that either.
At the opposite pole, would removal of Englebright help create a groundswell for removal of Folsom, or Shasta, or Pardee and Camanche, of Don Pedro or New Exchequer, or even of New Bullards Bar? That is simply not credible.
The immediate practical issue is whether a trap and haul program on the Yuba would stimulate other trap and haul programs in California. A process to evaluate a trap and haul program is already underway to move fish past Shasta Dam and Reservoir. It is making progress, but it is moving slowly. An icebreaker on the Yuba could provide motivation there. Further out on the horizon, studies are going on to look at reintroducing salmon and/or steelhead to the Tuolumne River upstream of Don Pedro Reservoir. A plan on the Yuba could give such an investigation more legs, particularly if the YSPI is successful in assembling multiple funding sources.
In sum, trap and haul on the Yuba is likely to create momentum for other locations in California where trap and haul is probably the best answer for reintroduction upstream of rim dams.
As for the rest of the country, let’s not forget that there are a dozen-odd trap and haul programs already underway in the Pacific Northwest. Some of them, like the program on the Cowlitz River, work very well, both economically and biologically. That didn’t stop the removal of Condit Dam on the White Salmon River. Different circumstances, different solutions. In both cases, fish passage was restored. Unlike California’s rim dams, where we haven’t even gotten started.
Is trap and haul right for the Yuba? 9. Conclusion (for now)
All in all, right now today, we believe that the YSPI is worth a serious and concerted effort. The habitat benefits appear largely better than they would with removal of Englebright Dam. There is more biological certainty that fish will get to where they need to go with a trap and haul program than there would be with Englebright Dam removal. There is a much greater likelihood of political success. There is much greater likelihood of raising enough money.
There are no guarantees, and there is a lot to work out. But for now, CSPA is in. We will make every effort to make the Yuba Salmon Partnership Initiative a success.