May 24, 2001

Mr. Darby Fuerst, General Manager

Monterey Peninsula Water Management District

P.O. Box 85

187 Eldorado Street

Monterey, California 93942-0085

Dear Mr. Fuerst:

The purpose of this letter is to establish the National Marine Fisheries Service's (NMFS) opposition to the proposed Carmel River Dam and Reservoir Project (CRDRP), and to express our support for expediting the development of off-stream water storage alternatives. It is NMFS' understanding that the District continues to expend resources on the environmental review and analysis of the CRDRP. We believe that resolution of the water supply problem is achievable without the CRDRP as proposed, and request that the District propose and develop viable water storage alternatives for evaluation. Specifically, the Monterey Peninsula Water Management District (MPWMD) should focus their effort toward developing alternatives such as the components of the Plan B alternative, and/or off-stream, pump storage reservoirs.

NMFS has reviewed previous environmental assessments for the proposed CRDRP, and provided comments on the Draft Supplemental EIR in a letter to MPWMD, dated January 15, 1999. In that letter we stated, "constructing a dam (CRDRP) with ten times the storage of the existing Los Padres Dam (LPD) will have significant effects on instream flow, cumulative barriers to fish passage, geomorphic channel and riparian function." Our overriding concern is that this project has the potential to significantly impact steelhead in a river that currently contains the most significant run of the South-Central California Coast Evolutionarily Significant Unit (ESU).

Steelhead returns to the Carmel River are already now less than 10% of historic levels. The construction of the CRDRP could adversely affect runs of adult steelhead in downstream reaches, and it could preclude the recovery of steelhead in reaches upstream from the new dam. Our apprehension regarding the new onstream dam stems from two issues: 1) the potential adverse effects of a major storage reservoir on downstream flows, and 2) the loss of spawning and rearing habitat upstream from the new reservoir as well as the inability of juveniles and smolts to migrate through the reservoir.

The identification and development of an off-stream water supply project are essential to resolving Carmel River fish and wildlife issues, providing residents a firm supply of water, and for preserving the economic integrity of the Carmel Valley. Currently the development of the Carmel River Habitat Conservation Plan (HCP) is stalled due to questions surrounding how to provide more flow in the Carmel River for steelhead. We have informed Cal Am and the Carmel River Joint HCP Committee that a new, 24,000 acre-foot (AF) onstream dam is likely to jeopardize the continued existence of the South-Central California Coast steelhead ESU, for the reasons discussed more fully below. We do not believe that the impacts of such a project can be minimized or mitigated, and therefore a new 24,000 AFonstream dam will not meet the criteria specified in the Endangered Species Act (ESA) and applicable regulations for the issuance of either an incidental take statement under section 7 of the ESA or an incidental take permit under section 10 of the ESA.

Potential Flow-related Impacts of a New Dam

The CRDRP would have a very significant effect on the hydrology of the Carmel River. The proposed project would impound almost all of the project inflow, except for minimum levels prescribed for fisheries maintenance. Operating rules for the project would provide substantial flow for summer and fall rearing habitat for steelhead. However, in exchange for relatively high summer flows, the CRDRP would effectively impound most of the project inflow during the winter and spring months. R2 Resource Consultants (2000) report that the project's proposed 24,000 AF reservoir would have the capacity to impound about 45% of the surface flow during normal water years. This is a statistical approximation that discounts the numerous years when virtually all of the flow would be impounded except for minimum releases for fisheries. Proration of estimated unimpaired flows at the USGS gage at Robles del Rio (assuming an average rainfall of 22 inches and a drainage of 193 square miles at Robles del Rio, and an average rainfall of 27 inches and a drainage of 44.8 square miles at the CRDRP (Bechtel Civil Inc. 1989)) indicates that annual inflow to the CRDRP would fill the 24,000 AF reservoir in about 38% of the years, if there were no fisheries maintenance flow releases. Thus, in most years the project would likely impound all of the project inflow, except for the minimum levels allocated for fisheries protection. This we find unacceptable.

The CRDRP would produce a highly artificial hydrograph that would affect steelhead in reaches downstream from the proposed dam. Although flow releases during June through December would be much better than existing conditions, the capture of most of the winter and spring flow would impair the river's stream channel and reduce flows needed for smolt emigration.

MPWMD (1998b) examined the effects of the CRDRP on channel maintenance flows in reaches downstream from the project. That document states that, "it is assumed that potentially significant impacts on aquatic habitat could occur in reaches where the incipient particle class could be reduced by 10% or more." That analysis indicates that incipient particle class would be reduced by more than 10% in areas between San Clemente Dam and the Narrows and between the new dam and Cachagua Creek. Although these areas are already impacted by the loss of sediment supply due to the existing Los Padres and San Clemente Dams, substantial alteration of natural winter flows by the new dam may exacerbate channel impacts in reaches downstream of the Los Padres Dam. Reducing the magnitude and duration of high flow events can induce channel narrowing and sedimentation from fines produced from downstream sources (Kondolf and Williams 1999).

Our concerns about the CRDRP effects on downstream migrating smolts are based on previous analysis of steelhead returns and the possible implications of maintaining a static minimum flow during April and May. The CRDRP operations plan calls for a minimum flow of 40 cfs during April and May, in "normal or better" and "below normal" years. Snider (1983) conducted a limited analysis of the relationship between spring flows (April and May) and adult steelhead returns two years later. He found that   in years when spring flows at the Robles del Rio gage were regularly above 350-400 cfs, adult returns were very good two years later. He suggests that high spring flows contribute to high smolt survival, which in turn contributes to high adult returns. When adjusted for differences in drainage area and precipitation, flows of 350-400 cfs at Robles del Rio are equivalent to flows of about 100 cfs at the CRDRP site. This is considerably more than the 40 cfs prescribed for the spring period. In addition, the new project would probably be operated with sustained minimum flows throughout much of the smolt migration period. Maintaining a constant minimum flow throughout April and May would reduce or eliminate natural freshets that can be cues triggering downstream migration of salmonid smolts (Randall et al. 1987; Bjornn and Reiser 1991; Sandercock 1991).

Potential Effects of a New Dam on Steelhead Habitat and Smolt Emigration

The CRDRP has a strong potential to eliminate existing or potential steelhead habitat in the 44.8 square mile watershed located upstream of its 282 ft high dam. The California Department of Water Resources (2000) estimated that about 29% of steelhead rearing habitat in the Carmel River watershed is upstream of the proposed CRDRP. That habitat is of the highest quality (Snider 1983). Most rearing habitat upstream from Los Padres Dam is within the Ventana Wilderness area, where river flow is unregulated, roads have not caused erosion, and bedrock outcrops control the course of the channel (MPWMD 1998b). Steelhead production in this area is presently limited. Only a small percentage of the fish that are able to successfully pass the San Clemente Dam are captured and trucked upstream of the Los Padres Dam. The restoration and recovery of steelhead in reaches above Los Padres Dam can be achieved. A new trap and truck collection facility has been installed at the existing Los Padres Dam and downstream passage facilities can be provided. However, the construction of a new 282 ft high onstream dam with a 24,000 AF reservoir would probably preclude the future recovery of steelhead in this pristine portion of the watershed. The CRDRP would impound more than two miles of high quality steelhead rearing habitat, and it would form a potentially insurmountable obstacle to downstream migrating smolts. Assuming a conservatively small reservoir width of 300 ft, a depth of 100 ft, and an estimated median monthly flow through the impoundment of 17 cfs during April, the average current velocity through the reservoir would be 0.0006 feetper second (ft/s). Assuming the same width and depth and a median monthly flow of 6 cfs through the impoundment in May, the average velocity in May would be 0.0002 ft/s. Currents in the impoundment would be essentially undetectable during the spring outmigration. Reservoir systems that store a relatively large proportion of the annual runoff are frequently unsuccessful at passing anadromous salmonids, often because of the difficulty in attracting downstream migrants to collection facilities near the spillway (R2 Resource Consultants 2000). For this reason, the CRDRP includes a smolt trapping facility located at the upstream end of the project reservoir. However, R2 Resource Consultants (2000) point out that the proposed approach to trapping is an unconventional and unproven technology, and it is vulnerable to malfunction due to debris loads. In order to limit potential debris and sediment problems, the downstream collection facility would be shut down during the high flow months of January and February. Yet, it remains unclear whether juvenile steelhead would move downstream into the impoundment at that time. For example, Snider (1983) states that it appears that juvenile steelhead in the Carmel River initiate downstream migration during the early rainy season, from late fall to early winter. He suggests that they move to the lower river where growth conditions are more favorable. Another problem with the proposed smolt trapping facility is that it would be situated on the Carmel River and would not facilitate passage for smolts emigrating from Danish Creek, which would become a tributary to the reservoir. The California Department of Fish and Game has expressed similar concerns regarding the downstream passage issue. For these reasons, we do not support the proposed downstream passage facilities.

Given these concerns we recommend that you consider alternative water storage facilities rather than focusing upon a new, large onstream reservoir. Such alternatives may include the Plan B components identified by the California Public Utility Commission or an alternative plan involving one or more large offstream reservoirs, including potential sites at Ft. Ord. The recovery of a self-sustaining, naturally-reproducing run of steelhead in the Carmel River is an achievable goal. The substantial alteration of the winter and spring hydrographs in theupper watershed and loss of habitat due to the new dam could preclude that recovery.

We look forward to working with you to solve the difficult problem of water supply and related environmental protection in the Carmel Valley. If you have questions regarding this letter, please contact Mr. Patrick Rutten at 707-575-6059; or for technical questions, contact Dr. Bill Hearn at 707-575-6062.

Sincerely,

Rebecca Lent, Ph.D.

Regional Administrator

cc: J. Lecky - NMFS

S. Farr - U.S. Congress

F. Keeley - CA State Assembly

D. Noda, D. Pratt - USFWS

H. Schueller - SWRCB

F. Curry - CPUC

R. Floerke - CDFG, Yountville

K. Urquhart - CDFG, Monterey

M. Lucca - Cal Am

Literature Cited

Bechtel Civil Inc. 1989. Monterey Peninsula Water Supply Project, New Los Padres, New San Clemente and San Clemente Creek Projects, Preliminary designs and cost estimates. Prepared for the Monterey Peninsula Water Management District, Monterey, CA.

Bjornn, T.C., and D.W. Reiser. 1991. Habitat requirements of salmonids in streams. American Fisheries Society Special Publication 19: 83-138.

DWR. 2000. Recirculated draft environmental impact report for the seismic retrofit for the San Clemente dam. California Department of Water Resources.

Kondolf, G.M., and J.G. Williams. 1999. Flushing flows: a review of concepts relevant to Clear Creek, California. Prepared for U.S. Fish and Wildlife Service, Red Bluff, CA.

MPWMD. 1994. Monterey Peninsula Water Supply Project, Final EIR/EIS, Monterey Peninsula Water Management District, Monterey CA.

MPWMD 1998a. Draft supplemental environmental impact report for the Carmel River Dam and Reservoir Project, Volume 1: Chapters 1-14. Monterey Peninsula Water Management District, Monterey CA.

MPWMD 1998b. Draft supplemental environmental impact report for the Carmel River Dam and Reservoir Project, Volume 2: Appendices. Monterey Peninsula Water Management District, Monterey CA.

R2 Resource Consultants. 2000. Review of Carmel River Dam fish passage facilities. Prepared for Monterey Peninsula Water Management District, Monterey, CA. 31 pp

Randall, R.G., M.Healey, and J. Dempson. 1987. Variability in length of freshwater residence of salmon, trout, and charr. American Fisheries Society Symposium 1: 27-41.

Sandercock, F.K. 1991. Life history of coho salmon (Oncorhynchus kisutch). pp. 395-446 In

C. Groot and L. Margolis [eds.] Pacific salmon life histories. UBC Press, Vancouver, BC.

Snider, W. 1983. Reconnaissance of the steelhead resource of the Carmel River drainage, Monterey County. California Dept. Fish and Game, Environmental Services Branch.