CSPA
Oroville Stocking June 1997
CALIFORNIA SPORTFISHING PROTECTION ALLIANCE
P.O. BOX 357
QUINCY, CALIFORNIA 95971
LAKE OROVILLE FISH ENHANCEMENT COMMITTEE
5360 TREASURE HILL DRIVE
OROVILLE, CA 95966
Mr. Eric See, Fisheries Biologist June 18, 1997
Oroville Field Division
Division of Operations and Maintenance
California Department of Water Resources
460 Glen Drive
P.O. Box 1191
Oroville, CA 95965
Re: Lake Oroville Draft 90 Day Report - February Through April 1997; FERC Project No. 2100; Feather River Project; Feather River and Tributaries, California; Comments by California Sportfishing Protection Alliance and Lake Oroville Fish Enhancement Committee
Dear Mr. See:
As required by the Federal Energy Regulatory Commission (FERC) in their February 28, 1995 FERC Order, the CDWR is required to submit reports on its Lake Oroville Fish Stocking Study with FERC every 90 days. Said report is required to include comments from the California Sportfishing Protection Alliance, Lake Oroville Fish Enhancement Committee, U.S. Fish and Wildlife Service, and the California Department of Fish and Game, in the event comments are submitted to CDWR.
We have reviewed the draft Lake Oroville 90 day report from the period from February to April, 1997. The following are the comments of the California Sportfishing Protection Alliance and the Lake Oroville Fish Enhancement Committee:
1. The draft report under Lake Oroville Creel Census should disclose and explain the flooding event in late 1996 and early 1997, and the effects to water quality (turbidity) and the resulting effects to sportfishing for salmonids in Lake Oroville (aka Oroville Reservoir). It should be noted that turbidity and the resulting effects to sportfishing (trolling) probably precluded a significant amount of sportfishing for salmonids at Oroville Reservoir and affects the CDWR data base.
2. The draft report discloses that the 42 foot boat which is proposed to be used for midwater trawling was used to clean up floating debris in the reservoir. The draft report should disclose the areas (surface area - acres - locations) in the reservoir which were closed to sportfishing due to debris. It should be noted that areas in the reservoir closed to sportfishing by debris affects the CDWR data base.
3. The draft report discloses that the 42 foot boat which is used for midwater trawling was used to clean up floating debris in the reservoir. The draft report should disclose the total number of days midwater trawling was conducted in the reservoir since commencement of the study. It should be noted that, regardless of the alleged circumstances involving the use of the boat for midwater trawling during the period of the study, that lack of trawling information affects the CDWR data base.
4. The draft report under Electrofishing Data shows the species of fish sampled on March 17, 1997. The draft report data base shows that 3979 seconds were conducted in conducting the electrofishing. We understand that the counting, measuring, and weighing of fish takes additional time.
There is about 187 miles of shoreline along Oroville Reservoir. Considering that the CDWR and CDFG were concerned that the stocking of salmonids in the reservoir could affect warm water species of fish, including pond smelt (wakasagi), we are surprised at the very limited amount of time being used by CDWR to conduct electrofishing surveys.
The draft report should disclose the specific locations in the reservoir where the electrofishing took place.
The Electrofishing Data shows the number of fish collected, mean length, number of fish weighed, mean length of weighed fish, and the mean weight.
It is our understanding some fish will float and some fish like bass will sink when shocked by electrofishing devices, and also some fish will be harmed (dead). We have consulted with fishery biologists to reach this conclusion.
The draft report should show the specific losses to all species of fish from electrofishing. And the draft report should explain how dependable electrofishing is in determining fish populations in reservoir environments. It is our understanding electrofishing is not exact, and that snorkeling is far better, and does not harm fish species. It should be noted that snorkeling surveys were conducted on the Upper Sacramento River to determine fish populations levels. i.e. Post SP railriad spill.
Also, to date, we have not reviewed any reports that shows the effects to bass spawning (nests, etc.) resulting from fluctuating reservoir levels at Oroville Reservoir. We recommend that the effects to bass spawning resulting from fluctuating reservoir levels be included in future reports. It should be noted that without this data base, the planting of salmonids could be blamed for reduction to bass populations, should reductions occur.
Please include an explanation in the draft report why salmonids were not found in the electrofishing survey of March 17, 1997.
5. The draft report under Hatchery Production Reports does not include a written explanation regarding the CDFG monthly egg and fish transaction reports, and how that data relates to the fishery study and the planting of surplus fall-run chinook salmon into Oroville Reservoir and other reservoirs. The draft report should be changed to include a written explanation regarding the hatchery data in the draft report and how that data relates to the fishery study and the planting of surplus fall-run chinook salmon into Oroville Reservoir and other reservoirs, including other related fishery issues in Oroville Reservoir.
6. The data base in the draft report consistently shows that the data is "preliminary - subject to revision" (12 pages).
LOFEC, CSPA, and other parties such as the USFWS are being asked to submit comments pertaining to data in the draft report which have been deemed "preliminary - subject to revision" by the CDWR.
In fact it appears that all data pertaining to the on-going study is "preliminary - subject to revision".
We have not been advised by either CDWR and CDFG in the past following the submittals of "preliminary - subject to revision", when there were changes to the data base in final reports submitted to the Federal Energy Regulatory Commission.
Changes in the data base could affect the results of the on-going study, and also could affect comments made by the CSPA, LOFEC, USFWS, and other parties based on the "preliminary - subject to revision" data.
Please include an explanation in the draft report regarding the following:
(a) Have changes to the data base shown as "preliminary - subject to revision" been made by either CDWR and CDWR with or without formally advising the FERC, LOFEC, CSPA, USFWS, and other parties?
(b) If so, what were the changes to the data base in "preliminary - subject to revision" documents.
(c) When does the data shown as "preliminary - subject to revision" become final.
(d) We also need to know the reasons why this and other data is "preliminary - subject to revision".
7. We have reviewed "Funding Appropriations and Cost Estimates" in the draft report. We believe the draft report should include the specific funding sources and the specific cost estimates. We believe the public is entitled to have information regarding the specific sources of funding (state and federal funding) and specific line item costs. (Our Emphasis)
We are requesting the following be included in the draft report:
February - April 1997 (Past Expenses)
(a) The specific line items in dollars for personnel/operations. Note $30,615 was spend. We need to know, and the public need to know, the specific money spend on personnel, and also on operations.
(b) The specific line items in dollars for equipment/additional expenses. Note $6,886 was spend. We need to know, and the public need to know, the specific money spend on equipment and additional expenses.
(c) The specific line items in dollars for personnel/operations under Habitat Enhancement. Note $11,150 was spend. We need to know, and the public need to know, the specific money spend on personnel and operation under Habitat Enhancement.
(d) The specific line items in dollars for contracted labor under Habitat Enhancement. Note $23,996 was spend. We need to know, and the public need to know, the specific money spend on contracted labor under Habitat Enhancement.
(e) The specific line items in dollars for equipment under Habitat Enhancement. Note $426 was spend. What type of equipment was purchased.
May - July 1997 (Past and Future Expenses)
(a) The specific line items in dollars for personnel/operations. Note $38,670 will be spend. We need to know, and the public need to know, the specific money spend on personnel, and also on operations.
(b) The specific line items in dollars for equipment/additional expenses. Note $6,500 will be spend. We need to know, and the public need to know, the specific money spend on equipment and additional expenses.
(c) The specific line items in dollars for personnel/operations under Habitat Enhancement. Note $130 will be spend. We need to know, and the public need to know, the specific money spend on personnel and operation under Habitat Enhancement.
We are also requesting a full public disclosure and public accounting, based on specific line items in dollars spend since the commencement of the study and 90 day reporting process, commencing with each 90 day report to the Federal Energy Regulatory Commission.
8. The draft report under Stocking Schedule states that 100,000 chinook salmon fingerlings were stocked in Oroville Reservoir during the first week of June. And that the 1997 yearling chinook salmon allotment for Oroville Reservoir will not be determined until the fall of 1997 - however, 250,000 yearlings will be available for stocking in Oroville Reservoir.
The draft report should disclose and explain why the determination regarding the specific number of chinook yearlings to be planted in Oroville Reservoir is determined in the fall of the year. And the reasons for stocking 100,000 fingerlings and maybe 250,000 yearlings in the reservoir.
The draft report under Stocking Schedule states that during March of 1997, a total of 421,690 chinook salmon were tagged with coded wire tags. And that this included two groups of fish; a group of 105,467 that will be used for the fingerling allotment, and a group of 316,223 that will be grown out to supply the yearling allotment.
We were advised by Banky Curtis, Regional Manager, CDFG, at a meeting with Assemblyman Bernie Richter, that the stocking of chinook salmon at Oroville Reservoir was being made on a trial and error basis. (Our Emphasis)
We are requesting that 316,223 chinook salmon yearling are planted in Oroville Reservoir in the fall of 1997.
In the event any of the 316,223 chinook salmon yearlings, which are available for Oroville Reservoir, are planted at other reservoirs in the state, we are requesting the subsequent 90 day report show where those yearlings were planted (reservoirs) and the number of yearlings planted in those reservoirs which were reared at the Feather River Hatchery.
The draft report did not disclose the locations where the chinook fingerlings were planted. The draft report should include the specific locations where the 100,000 were planted in the spring of 1997.
9. The draft report did not disclose and include the number and size of brown trout proposed for planting in the reservoir in 1997.
We recommend that catchable brown trout are planted in the reservoir in 1997 which are consistent with, or in addition to brown trout planted in the past.
10. Past 90 day reports to the FERC have not disclosed the locations where the chinook salmon yearlings were planted in Oroville Reservoir. The locations where chinook yearlings are planted is very important. The same is true of brown trout planted in the reservoir.
As stated beforehand, there are 187 miles of shoreline in Oroville Reservoir. There are four major "arms" of the Feather River that flow into Oroville Reservoir. Those "arms" are the North Fork Feather River Arm, the Middle Fork Feather River Arm, the South Fork Feather River Arm, and the West Branch Feather River Arm. And there is the main body of Oroville Reservoir. i.e. five locations.
The draft report should disclose the locations of Oroville Reservoir where chinook yearlings and brown trout are planted, including the specific number of fish planted at each location.
11. The draft report did not disclose the effects to water quality and fishery habitat resulting from sediment in all "arms" of the reservoir as a result of the flooding flows of late 1996 and early 1997.
It is our understanding that sediment might have effected the fish at the Feather River Hatchery. And that PCB's have been detected at the Oroville Powerhouse.
The draft report should explain the effects to water quality and fishery habitat in all arms of the reservoir as a result of the recent flooding event, including the Feather River Hatchery. And the draft report should explain future mitigation measures to combat sediment and PCB's entering Oroville Reservoir.
That concludes the comments of LOFEC and the CSPA. Please include our comments in the 90 report. We are also requesting the draft report is amended as requested in our letter of comment.
Respectfully Submitted
__________________________________________
Robert J. Baiocchi, Consultant
For: California Sportfishing Protection Alliance
Lake Oroville Fish Enhancement Committee
Butte County Citizens for Fair Government
P.O. Box 357
Quincy, CA 95971
Bus Tel: 916-836-1115 or 916-283-3767; Fax: 916-283-5017
Certificate of Service
Honorable U.S. Congressman Wally Herger
55 Independence Circle, Suite 104
Chico, CA 95926
Honorable Assemblyman Bernie Richter
State Capitol
Sacramento, CA 95814
Kevin Madden, Acting Director
Office of Hydropower Licensing
J. Mark Robinson, Director
Division of Project Compliance and Administration
Lon Crow, Director
Environmental Section
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
California Department of Water Resources, Licensee
c/o Rolland Williams, Sr., Chief
Oroville Field Division
460 Glen Drive
P.O. Box 1191
Oroville, CA 95965
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 Crenshaw, President
California Sportfishing Protection Alliance
1248 East Oak Avenue, Suite D
Woodland, CA 95695
Tom Van Gelder, Chairman
Lake Oroville Fish Enhancement Committee
5360 Treasure Hill Drive
Oroville, CA 95966
Mike Kelly, Chairman
Butte County Citizens For Fair Government
5055 Miners Ranch Road
Oroville, CA 95966
Jim Canaday, Environmental Unit
Section 401 CWA Coordinator
Division of Water Rights
California State Water Resources Control Board
P.O. Box 2000
Sacramento, CA 95812-2000
Maureen Rose
California Hydropower Reform Coalition
128 J Street, 2nd Floor
Sacramento, CA 95814-2207
Andrew Fahlund
Hydropower Reform Coalition
1025 Vermont Avenue, N.W., Suite 720
Washington D.C. 20005
Interested Parties
For further information contact Bob Baiocchi at either 530-836-1115 or
at e-mail address: cspa@psln.com