Lake Shasta and Sacramento River Operations: Lessons Learned – #1, Part 2

Following an introductory post, this is the second post in a series on the lessons learned by the National Marine Fisheries Service (NMFS) from the 2013-2015 drought that devastated Sacramento River salmon populations.  The first post addressed Lesson #1 and its non-application in the first half of 2020. 

This post addresses how the non-application of Lesson #1 in 2020 evolved into a tug-of-war in the second half of 2020 and has cascaded into non-action so far in 2021. For more detail and links, see CSPA’s March 15, 2021 letter to the State Water Board urging immediate action to protect Sacramento River and Delta fisheries in 2021.  See also the State Water Board’s Sacramento River Temperature web page, though some of the links are not live, at: https://www.waterboards.ca.gov/waterrights/water_issues/programs/drought/sacramento_river/index.html

Water and fisheries managers have known for many years that both the Lake Shasta storage level on April 1 and spring releases from Shasta determine how much cold water will be available in the lower Sacramento River through the summer.  However, in 2020, as discussed in Part 1 of this series, the Bureau of Reclamation (Reclamation) refused to decide on water temperature management options for Shasta Reservoir and the lower Sacramento River before April 1.  Reclamation submitted a draft temperature management plan (TMP) to the State Water Board on April 23 and a final TMP on May 20, neither of which evaluated reduced delivery options whose analysis the State Water Board had requested.

Meanwhile, Reclamation was operating in 2020 in the first year of the new Trump-era Biological Opinions for the long-term operation of the Central Valley Project (CVP) and the State Water Project (SWP).1 The stated purpose of these Opinions was to “maximize deliveries” of water to contractors, and did they ever deliver.  See part of the results in Figure 4 of the previous post: very high deliveries to Sacramento River CVP contractors in April and May, so that water in Lake Shasta was committed before the plan to operate Shasta was complete.

By June 1, 2020, the State Water Board had rejected Reclamation’s TMP.  In its June 1, 2020 letter refusing Reclamation’s May 20 TMP, the State Water Board wrote:

Reclamation has declined to evaluate additional operational scenarios. Reclamation’s position is that scenarios with different operational assumptions would be inconsistent with its contractual obligations, and are therefore beyond Reclamation’s reasonable control. The State Water Board disagrees. To the extent that Reclamation delivers water under its own water rights, Reclamation’s obligation to deliver water to its contractors does not take precedence over its permit obligations.

On July 17, 2020, CSPA and its partners reached a settlement agreement with the State Water Board that dealt in substantial part with Sacramento River temperature management.  The settlement agreement requires the State Board to conduct a transparent Sacramento River Temperature Management process.  The process must address all controllable factors, including deliveries, and ensure adequate staffing, modeling and public review.  The CSPA settlement became part of the dispute between Reclamation and the State Water Board in the following months.

After exchanges of letters between Reclamation and the State Water Board in June and July, and an addendum to the TMP on July 31, the State Water Board gave up on 2020 and in an August 4 letter  tentatively approved the TMP, subject to conditions, two of which stated:

  • Reclamation shall develop a draft protocol by September 30, 2020, that meets the criteria identified by the State Water Board;
  • By September 15, 2020, Reclamation shall provide additional information concerning fall operations, including the volume and timing of releases and deliveries each month through December.

On August 31, the State Water Board sent a follow-up letter clarifying its request of Reclamation:

As part of the State Water Board’s conditional approval of Reclamation’s 2020 Temperature Management Plan (TMP), Reclamation is required to develop an initial draft protocol by September 30, 2020. The State Water Board will hold a public workshop this fall in coordination with Reclamation to receive public comment on the initial draft protocol to inform its completion. Once public comments are received, the Board intends to work with Reclamation to refine and finalize the protocol before the beginning of the next temperature planning and water supply allocation season in February 2021. The Board has requested that the protocol include the elements specified in the settlement agreement with the California Sportfishing Protection Alliance, et al., which the Board recently forwarded to Reclamation. This letter provides additional detail regarding issues that should be addressed as part of the protocol.

None of it happened.  No protocol.  No public workshop.  No public comments.  No disclosure to the State Water Board of the timing and releases of release and deliveries from September through December.  No final protocol by February 2021.  Instead, one final letter from Reclamation on September 30, deflecting the issue to the settlement with CSPA even though the issues in the settlement were issues raised by the State Water Board months before the settlement was completed: “Reclamation does not consider a state court voluntary settlement, to which Reclamation is not a party, as valid, enforceable legal requirements imposed on Reclamation.”

After all the correspondence, Reclamation affirmed on September 30 that it was right the first time: “The process for analyzing conditions and incorporating the best information into water management decisions for temperature management at Shasta Reservoir is outlined in the Shasta Cold Water Pool Management Flow Guidance document which was shared with the State Board staff on April 2, 2020.”

And so it comes full circle.  Faced with adversity last fall, the State Water to date performed as it all too often has: it has done nothing.  The Ides of March have passed, and there is every sign that the State Water Board will for a second straight year allow Reclamation to once again defy Lesson #1: Keswick releases need to be decided by April 15.

No Delta Smelt Fall 2018

Though I hate to “beat a dead horse” or perhaps more appropriately “put another nail in the coffin,” I’m sad to report that the California Department of Fish and Wildlife’s first two fall trawl surveys for 2018 collected no Delta Smelt. This is consistent with this past summer’s townet survey results. Let’s get on with implementing the smelt hatchery program.

Fall mid-water trawl survey catch for September and October 2008-2018. Data source: http://www.dfg.ca.gov/delta/data/fmwt/indices.asp

PG&E Withdraws License Application on Butte Creek: Future of Spring-Run Salmon Uncertain

By Chris Shutes (CSPA) and Dave Steindorf (American Whitewater)

In a surprise move, PG&E announced on February 2, 2017 that it was withdrawing its application to relicense the DeSabla – Centerville Hydroelectric Project on Butte Creek and the West Branch Feather River.  The reach of Butte Creek affected by the Project is home to the only remaining viable population of spring-run Chinook salmon in California’s Central Valley.

Spring-run salmon in Butte Creek have seen a resurgence over the last twenty years.  A substantial part of this was due to investments and improvements downstream of the Project. In addition, since 2003, PG&E and state and federal resource agencies have greatly improved the management of the Project for the fish.

From 2004 to 2009, PG&E went through a formal relicensing process with the Federal Energy Regulatory Commission (FERC) to relicense the Project.  In 2016, the State Water Board issued a Water Quality Certification needed for a new license.  A new license from FERC was widely expected in 2017.

In a DeSabla – Centerville fact sheet and map that PG&E distributed with its announcement, PG&E describes the project as follows:

The Project diverts a portion of the natural flow of water from Butte Creek and West Branch of the Feather River (WBFR) into canals that carry the water for use in hydroelectric powerhouses. Once water is run through the powerhouses it is ultimately released to Butte Creek. During the summer, the natural flow of the WBFR is augmented by water releases from Round Valley and Philbrook reservoirs. Project diversions have provided additional flow to Butte Creek for more than 100 years. One of the beneficiaries of this additional flow has been the aquatic community in Butte Creek, including Central Valley spring-run Chinook salmon.

While it is true that water from the Project augmented flows below Centerville Powerhouse for 100 years, it is only since 1980 that the Project benefited fish in the eight miles of Butte Creek between DeSabla Powerhouse and Centerville (see map).  The 2016 Water Quality Certification requires all the Butte Creek water and the imported water to remain in Butte Creek once it exits DeSabla Powerhouse.

The DeSabla – Centerville Project facilities are built around infrastructure that dates to 1900 and in some cases before.  Commissioned in 1900, Centerville Powerhouse has been offline since 2011, and ran only partially for the five years previous to that.  To function at all, it would need a complete rebuild.  The estimated cost to rebuild was $39 Million in the mid-1990’s; it is almost certainly now double that, or more.  DeSabla Powerhouse, nine miles upstream of Centerville, is relatively modern and in good condition, but the small reservoir that feeds it allows water to heat up too much passing through.

In California’s modern energy market, the capability to regulate the grid gives hydropower its greatest value.  But unlike many other hydropower projects, powerhouses in the DeSabla – Centerville Project run at a constant rate, day and night, regardless of when power demand is high or low.  They also have no ability to help regulate the power grid, especially to respond to short-term changes in supply from intermittent renewable sources like wind and solar.

The real value of the Project is the water it imports from the West Branch Feather River to Butte Creek: value for the fish and value for the farms that use the water further downstream.  The fish can’t pay for this service; the farms have never been asked to pay and never have.

PG&E’s decision not to relicense the Project does not lead to a path that is simple.  In the next few months, moving into the next few years, PG&E will need to establish a stakeholder engagement process to help determine the Project’s long-term disposition.  PG&E will need to engage resource agencies, downstream water rights holders, interested NGO’s, and local residents.  The DeSabla – Centerville Project has been part of the community for over a century.  Its resource values are enormous.  The water that it supplies downstream is essential to the irrigation of thousands of acres of crops.

On September 19, 2015, PG&E bought an advertisement on the editorial page of the San Francisco Chronicle entitled:  “Of Bees, Birds and Chillin’ Chinook: All in a Sustainable Day at PG&E.”  Mr. Tony Earley, CEO of PG&E at the time, started the ad by extolling PG&E’s work to keep salmon in Butte Creek cool.  His major theme stated: “The days are long past when energy companies could afford to think of their mission as separate from conservation, sustainability and good management of our natural resources.  Our view must be for the long term.  That’s why we live our commitment to conservation through a number of programs.”

We look forward to the opportunity to help PG&E maintain this well-stated goal.