CSPA

Letter to the US Army Corps of Engineers

Subject: CSPA Action - The Fish Screen

Date: Mon, 10 Nov 1997 16:38:44 +0000

From: Bob Baiocchi <cspa@psln.com>

Organization: CSPA

To: Distribution (email list of CSPA supporters and other interested parties)

CALIFORNIA SPORTFISHING PROTECTION ALLIANCE

P.O. BOX 357

QUINCY, CALIFORNIA 95971

Colonel Dorothy F. Klasse November 10, 1997

District Engineer

Sacramento District

U.S. Army Corps of Engineers

1325 J Street

Sacramento, CA 95814-2922

Re: Public Notice No. 199700567; Glenn Colusa Irrigation District,

Appliant; Draft Environmental Impact report/Environmental Impact

Statement; Hamilton City Pumping Plant Fish Screen Improvement Project,

Northern Sacramento Valley, California; Sacramento River; Comments by

California Sportfishing Protection Alliance regarding COE Public Notice

199700567 and Draft EIR/EIS

Dear Colonel Klasse:

We have reviewed Public Notice 199700567 regarding Glenn Colusa

Irrigation District's (GCID) application for a Department of the Army

permit under the authority of Section 10 of the Rivers and Harbors Act

and Section 404 of the Clean Water Act to modify GCID's Hamilton City

Pumping Plant facilities in the Sacramento River. We reference said COE

notice of October 3, 1997.

We have also reviewed the Draft EI/EIS for the Hamilton City Pumping

Plant Fish Screen Improvement Project, Northern Sacramento Valley,

California; Sacramento River. We reference said EIR/EIS [State Clearing

House No. 93062042].

We are writing directly to the COE because of the following

information. The California Sportfishing Protection Alliance (CSPA)

filed a complaint with the State Water Resources Control Board (SWRCB)

against GCID about ten years ago requesting the SWRCB to order GCID to

modify the existing fish screen because of adverse impacts to the

people's chinook salmon and steelhead trout resources. The SWRCB

referred the complaint and that fish screen matter to the COE.

We are concerned about the length of time it has taken the COE, other

state and federal agencies, and GCID, to finally recommend to modify the

pumping facilities. Disclose and include an estimate as to the number of

chinook salmon and steelhead entrained and harmed at the pumping

facility in the draft EIR/EIS for the past ten years. The Draft EIR/EIS

has five alternatives. The alternatives are: (1) No-Project Alternative;

(2) Screen Extension Alternative; (3) Screen Extension with Gradient

Facility; (4) Screen Extension with Gradient Facility and Internal Fish

Bypass (Return to Oxbow); and (5) Screen Extension with Gradient

Facility and Internal Fish Bypass (Return to River). The highest rated

alternative is the Screen Extension with Gradient Facility and Internal

Fish Bypass (Return to Oxbow). The lowest rated alternative is the No

Project Alternative.

The alternative selection decision will be made collectively by the

COE, U.S. National Marine Fisheries Service, U.S. Fish and Wildlife

Service, Department of Fish and Game, U.S. Bureau of Reclamation,

including GCID.

We are opposed to the "No Project Alternative". The "No Project

Alternative is likely to jeopardize the continue existence of winter-run

chinook salmon. See 16 USC Section 1536(a) [ESA].

The fish screen to be selected and constructed should be the

alternative that will be the most effective in preventing entrainment,

harm, and losses to winter-run chinook salmon, and other races of

chinook salmon, steelhead trout, and other fish species.

Fish screens are not 100% effective. Consequently, there must be a long

term monitoring program to determine the number and species of fish

entrained, harmed, and lost at the pumping facility. GCID should be

required to fund the cost of the annual monitoring program and plan. The

final EIR/EIR should include the recommended monitoring program and

plan. This would be reasonable since the taxpayers will be footing a

large part of the construction cost of the proposed project. And the

taxpayers were not at the table when the cost of the fish screen was

negotiated between GCID and the state and federal agencies.

Fish screens are not 100% effective. GCID should also be required to

compensate the people for all losses to fish species entrained, harmed,

and lost at the new fish screen facility. Compensation should be in the

form of a trust fund for the purpose of anadromous fishery restoration

and protection projects.

All potential direct, indirect, and cumulative impacts to the human

environment resulting from the construction of the new fish screen

should be disclose, evaluated, and fully mitigated in the draft EIS/EIS.

That concludes the comments of the CSPA. Please forward a copy of the

final EIR/EIS to me. Thank you.

Respectfully Submitted

_____________________________________________

Robert J. Baiocchi, Consultant

For: California Sportfishing Protection Alliance