CSPA and nine other Conservation Groups filed extensive comments and recommendations January 29, 2018 for flow requirements and non-flow measures for the lower Tuolumne River. The filing is an important milestone in the multi-year licensing process of the Don Pedro and La Grange dams owned by Turlock Irrigation District and Modesto Irrigation District. The comments make environmental recommendations and discuss legal requirements that the Federal Energy Regulatory Commission (FERC) must consider in evaluating license conditions for new hydropower licenses.
In their 124-page submittal, the Conservation Groups provide a detailed flow recommendation for the lower Tuolumne River. The recommendation modifies the State Water Resources Control Board’s plan to require the release of a percent of the unimpaired flow from February through June. CSPA used a hydrological model to develop the recommendation on how FERC and the State Water Board could balance flow, irrigation and municipal water supplies, and reservoir storage. The recommendation has specific provisions for droughts. It also proposes that the City of San Francisco fund groundwater recharge facilities for the irrigation districts in order to meet the City’s flow obligations for the river. With these new facilities, the irrigation districts could maintain groundwater levels with less reliance on water-intensive flood irrigation.
The Conservation Groups’ filing also recommends non-flow measures to create floodplain habitat, fill in dredger holes, replenish spawning gravel, and place large wood in the lower Tuolumne River.
The districts have 45 days to respond to all comments filed with FERC. The next major step in the relicensing process will be FERC’s preparation of the Environmental Impact Statement (EIS) under the National Environmental Policy Act (NEPA).
The Conservation Groups include CSPA, Tuolumne River Trust, Trout Unlimited, American Rivers, American Whitewater, Merced River Conservation Committee, Friends of the River, Golden West Women Flyfishers, Central Sierra Environmental Resource Center, and Tuolumne River Conservancy.