CSPA
CSPA Letter to the Eldorado National Forest Supervisor
Re: Upper Mokelumne River Watershed
Subject: CSPA Action - Upper Mokelumne River Watershed
Date: Mon, 10 Nov 1997 16:32:23 +0000
From: Bob Baiocchi <cspa@psln.com>
Organization: CSPA
To: Distribution
CALIFORNIA SPORTFISHING PROTECTION ALLIANCE
P.O. BOX 357
QUINCY, CALIFORNIA 95971
John Phipps, Forest Supervisor November 6, 1997
Eldorado National Forest
U.S. Forest Service
100 Forni Road
Placerville, CA 95667
Re: Pacific Gas and Electric Company;Upper North Fork Mokelumne River
Project No. 137; Comments by California Sportfishing Protection Alliance
Dear Mr. Phipps:
On November 3, 1997 the Pacific Gas and Electric Company (PG&E) held a
meeting with state and federal agencies concerning a technical review of
very questionable fish and wildlife protection measures for the
relicensing of the Upper North Fork Mokelumne River Project No. 137.
PG&E limited the meeting to aquatic biologists and did not allow all of
the representatives from various intervenors and interested parties to
attend and take part at the meeting. Consequently, we believe our due
process rights were violated because of the limitation placed by PG&E on
who would be allowed to attend the meeting. The Eldorado National Forest
was represented at the meeting.
The California Sportfishing Protection Alliance is an intervenor for
the relicensing of the Upper North Fork Mokelumne River Project No. 137.
The fish and wildlife mitigation measures reached by some state and
federal agencies were based on an historic 1978 agreement. The
streamflow requirements in the 1978 agreement were developed well over
20 plus years ago. We believe that state of the arts instreamflow and
other environmental studies should be initiated at this place in time
because the 20 plus year old studies are old and out of date.
Since 1978 many species have been listed for protection under the
federal Endangered Species Act, and also under the protection of the
state Endangered Species Act. Also, the Eldorado National Forest
Resources Management Plan was prepared and finalized long after the 1978
agreement. Another new issue is the need to develop mandatory streamflow
requirements which meet the needs of whitewater boating, and that
whitewater test flows should be conducted.
In addition to the above shown issues and concerns, the 1978 Agreement
may not be in compliance with the standards and guidelines for the
Eldorado National Forest Resources Management Plan. And if that is the
case, the Management Plan would have to be amended to accommodate the
1978 agreement, in accordance with NEPA requirements.
Also, the State Water Resources Control Board has Section 401 Clean
Water Act authority and should be allowed to take part in this process
to protect the beneficial uses of the state's water.
The 1978 agreement flows are highly controversial among the public and
intervenors.
Consequently, it is very clear that new streamflow and environmental
studies need to be prepared in cooperation with intervenors and
responsible state and federal agencies.
The Forest Service has 4(e) authority and should play a major role in
the relicensing of the project so that the public trust resources
affected by the project are restored and protected adequately under
existing statutes.
In the future we expect the Forest Service and other state and federal
agencies to open any and all proposed meetings to intervenors to satisfy
their due process rights.
Please place the California Sportfishing Protection Alliance on the
mailing list, at the address shown below, for all submittals pertaining
to this matter.
If there are any questions, I can be reached at my office at
530-836-1115. My fax number is 530-283-5017. My e-mail address is
cspa@psln.com
Respectfully Submitted
_____________________________________________
Robert J. Baiocchi, Consultant
For: California Sportfishing Protection Alliance
P.O. Box 357
Quincy, CA 95971
Bus Tel: 530-836-1115 or 530-283-3767; Fax: 530-283-5017
Service List
Jim Crenshaw, President, CSPA
1248 East Oak Avenue, Suite D
Woodland, CA 95695
Jim Edmondson, Executive Director
California Trout
9770 Sombra Terrace
Shadow Hills, CA 91040
Richard Roos-Collins, Esquire
NHI
114 Sansome Street, Suite 1200
San Francisco, CA 94104
Maureen Rose, Coordinator
California Hydro Reform Coalition
Friends of the River
128 J Street
Sacramento, CA 95814
John Gangemi, Conservation Director
American Whitewater Affiliation
482 Electric Avenue
Big Fork, MT 59911
Pete Bell
Foothill Conservancy
P.O. Box 1255
Pine Grove, CA 95665
California Outdoors
P.O. Box 401
Coloma, CA 95613-0401
Gary Taylor, Energy and Power
U.S. Fish and Wildlife Service
3310 El Camino Avenue, Suite 130
Sacramento, CA 95821-6340
Banky Curtis, Regional Manager, Region II
California Department of Fish and Game
1701 Nimbus Road
Rancho Cordova, CA 95670
Jim Canaday, Environmental Unit
Division of Water Rights - SWRCB
P.O. Box 2000
Sacramento, CA 95812-2000
Interested Parties (numerous by e-mail)