On October 2nd, 2024, CSPA’s Chris Shutes delivered testimony before the Administrative Hearings Office (AHO) of the State Water Resources Control Board (State Water Board). Chris’s testimony disputed the talking points of the Sites Project Authority that the proposed Sites Reservoir would divert water only during periods of high flow in the Sacramento River. It also demonstrated how diversions to Sites Reservoir from the Sacramento River would offset the purported flow “additions” of the proposed Voluntary Agreements in many years. Finally, it showed how the claimed benefits to fish from exchanging water between Sites Reservoir and Shasta Reservoir are speculative and, even if they happened, would primarily benefit water supply.
Diversions to Sites Reservoir Would “Flatten” the Flows in the Sacramento River
In his testimony, Chris showed examples of what diversions to Sites would do to flows in the Sacramento River. Using examples from the flow records from 2000-2021, he showed how Sites diversions would have the greatest effects on Sacramento River flow when there was just enough flow for Sites to divert water. In Dry water years, Sites diversions would eliminate or reduce flow pulses in the Sacramento River. In the spring of somewhat wetter water years, Sites diversions would eliminate or shorten flow pulses. In all but the driest water years, Sites diversions would flatten flows in the Sacramento River as flows were dropping to the minimum flow requirement.
Though not part of Chris’s testimony, dry-year hydrological changes would be especially detrimental to fisheries in the Sacramento River and beyond. A paper by one of the Sites Authority’s witnesses shows dry-year flow pulses in the Sacramento River are twice as important for winter-run salmon as are flow pulses in wet year.
Sites Would Take Away All of the “Additional” Water from Proposed Voluntary Agreements in Above Normal Water Years
Sites Reservoir diversions would also negate additional flows from the proposed Voluntary Agreements that are intended to bolster Delta outflows. In Above Normal water years, Sites diversions would on average be greater than the flow additions of the proposed Voluntary Agreements. But not to worry, in Below Normal water years, Sites Reservoir diversions would reduce the Agreements’ “added” Delta outflow only by two thirds.
Proposed Environmental Benefits of Sites Reservoir are Speculative
The Sites Project Authority claims that the proposed Sites Reservoir would benefit fish, especially endangered anadromous species like winter-run Chinook salmon. The Sites Authority makes this claim based on its assertion that Sites reservoir could improve cold-water management in Shasta Reservoir.
Chris said that such benefits “are founded on the faulty assumption that “preserving storage” in Shasta Reservoir provides a benefit to fish rather than a water supply benefit.” “Exchanges of water between Sites Reservoir and Shasta Reservoir would primarily benefit water supplies and only incidentally provide any benefit to anadromous fish.”
In addition, purported benefits to fish would “depend on an unconcluded agreement between the Sites Authority and the Bureau of Reclamation (Reclamation) and are thus speculative and uncertain to occur.” To make matters worse, the State Water Board would have no authority to enforce any promises made by the Sites Project Authority.
CSPA Opposes Granting a Water Rights Permit for the Sites Reservoir Project
Sites Reservoir should not be granted a water rights permit. If the project moves forward, strict conditions must be imposed on the permit to “partially mitigate some of the greatest effects of diversions to Sites Reservoir on the Sacramento River hydrograph.” Such conditions include:
- The season of diversion should begin no earlier than December 1.
- The season for diversion should end no later than April 30.
- Diversions should not occur in Critically Dry, Dry, or Below Normal water years.
- If Voluntary Agreements are adopted by the State Water Board, diversions to Sites Reservoir should be restricted to Wet water years.
- Performance measures should be put in place to disallow diversions to Sites Reservoir whenever the purported benefits of prospective storage exchanges between Sites Reservoir and Shasta Reservoir are ineffective in preventing temperature dependent mortality and/or low egg-to-fry survival of winter-run Chinook salmon.
Watch the full testimony on YouTube
CSPA is committed to defending California’s fisheries and the ecosystems they depend on. CSPA will continue to fight this dangerous project and advocate for responsible water management that benefits California’s people and public trust resources.