Santa Ynez USBR Dealy CSPA comments on Draft EIR June96

CALIFORNIA SPORTFISHING PROTECTION ALLIANCE

P.O. BOX 357

QUINCY, CALIFORNIA 95971

Mr. J. Carl Dealy June 6, 1996

Natural Resource Specialist

South-Central California Area Office

Bureau of Reclamation

U.S. Department of the Interior

2666 North Grove Industrial Drive, Suite 106

Fresno, CA 93727-1551

Re: USBR - Draft Environmental Assessment for Bradbury Dam Modification - Final Seismic Corrective Emergency Remediation Work for Bradbury Dam; Santa Ynez River; USBR Cachuma Project; Santa Barbara County; California; Comments by California Sportfishing Protection Alliance.

By Fax: From 916-283-5017 (CSPA) to 209-487-5397 (USBR - Fresno Office)

Dear Mr. Dealy:

The following are the comments of the California Sportfishing Protection Alliance regarding the Draft Environmental Assessment prepared by the USBR regarding the proposed emergency dam repair work at Bradbury Dam.

1. "Bradbury Dam has undergone detailed and intensive investigations under Reclamation's Safety of Dams program (Modification Decision Analysis). These investigations indicate that moderate to severe earthquakes and rare flood events are potential threats to the integrity of the dam."

We reference Draft Environmental Assessment; Bradbury Dam Modification Seismic Corrective Action Safety of Dams Program; Prepared by U.S. Department of the Interior; Bureau of Reclamation, Mid-Pacific Region, South-Central California Area Office; Fresno, California; May 1996; at page 1 under Introduction and Background.

2. Public Health and Safety - "The existing conditions at the dam pose a significant threat to the downstream population. In the event of a catastrophic dam failure, approximately 37,000 lives would be at risk. Property damage downstream following a dam failure is estimated to be $1.6 billion. This estimate is for direct damage only and does not account for the long term economic losses which would be suffered by the community. The annual value of benefits foregone as a result of dam failure is estimated at $48.4 million." (Emphasis Added)

3. "Extensive data collected and analyses have shown that the downstream foundation alluvium of Bradbury Dam is susceptible to liquefaction. If liguefaction occurs, the embankment would slump both upstream and downstream due to the loss of foundation support. Reservoir water would overtop the collapsed embankment and rapidly develop a breach when the reservoir water surface is above 680 feet.A horizontal ground acceleration greater than approximately 0.15-0.20g is likely to trigger enough liguefaction of the saturated alluvium to cause failure of the downstream embankment. This level of horizontal ground acceleration is approximately equivalent to that which could be produced from a magniture 6.0 earthquake at 20 kilometers. Recent seismic studies have suggested that an acceleration of 0.2g has a 30 percent chance of exceedence in 30 years." (Emphasis Added)

The draft EA does not disclose the accountability of earthquake activity in the Cachuma Reservoir area during years since the dam was constructed. Heresay information shows that earthquakes in the Santa Barbara area in the 1800's caused tidal waves sufficient enough to place boats in the coastal area in upstream canyon areas. Heresay informations shows that earthquakes in the Santa Barbara area were very significant in the 1970's.

The final EA should disclose and describe past earthquake events in the Santa Ynez River basin and the resulting effects to the sea and land areas. The NEPA process requires full public disclosure. The draft EA should provide to the public a detailed accountability of past earthquake events in the area since recorded periods. The issue here is public health and safety in the downstream areas of the Santa Ynez River below Bradbury Dam.

4. "It was determined that the spillway walls might fail during severe earthquake shaking (see pg. 2). Failure of the walls would allow water flow between the spillway wall and dam embankment (when water surface elevation is above 720 feet) which can lead to an erosion failure of the dam." (Emphasis Added)

We reference Draft Environmental Assessment; Bradbury Dam ModificationSeismic Corrective Action Safety of Dams Program; Prepared by U.S. Department of the Interior; Bureau of Reclamation, Mid-Pacific Region, South-Central California Area Office; Fresno, California; May 1996; at page 3 under Failure of the Spillway Walls.

5. "Analysis of the spillway gates indicates that if the gates were subjected to a large earthquake (see pag.2) when the reservoir is near elevation 750 feet, failure would occur in the gate arms, leading to collapse of the gates. This could result in large uncontrolled spillway releases which could cause loss of life and severe economic damage." Emphasis Added)

Public Health and Safety

6. With all of the above mentioned data and information concerning potential adverse impacts to public health and safety at various reservoir elevation levels, the staff of the USBR "took a gamble (with people's lives) on impacts to public health and safety in the downstream area of the Santa Ynez River as follows:

a) "Reclamation also implemented a reservoir restriction in January 1995 requiring that the reservoir be restricted to the then current level of 733 feet which is 17 feet below the top of the spillway gates and 13 feet above the spillway crest. The reservoir capacity at 733 feet is about 144,000 acre-feet, or about 46,000 acre-feet lower than maximum capacity of 190,000 acre-feet." (Emphasis Added)

b) "During flood periods it was necessary to allow a rise in reservoir level above elevation 733 to maintain a safe discharge downstream from the dam. During the flooding events in early 1995 the elevation of the reservoir increased from 733.4 feet to 749.76 feet, essentially filling in a 24-hour period. Releases of flood water were than made to evacuate the surcharge above above elevation 733. Due to the recent success of the interim measures, the reservoir restriction to elevation 733 was recently lifted." (Emphasis Added)

We need to understand the truth of the issue. Has the potential earthquake impact due to liquefactor gone away and how does the interim measures prove that Bradbury Dam is stable in the interim period from a potential earthquake and dam failure.

c) "The reservoir will be allowed to fill to the top of active storage at elevation 750 feet contingent upon the continued success of the dewatering system. The dewatering system may become ineffective during spillway flows. If this occurs prior to implementation of the final corrective actions, the reservoir will be lowered to a level that would adequately protect the downstream public. The restruction of the reservoir elevation is independent of the seismic corrective action proposed in this environmental assessment."

7. The USBR claims due to the success of the interim measures, the reservoir restriction to elevation 733 feet was lifted. Disclose and describe in the Final EA whether an earthquake occured which provided the evidence that the interim measures were successful. In the event an earthquake did not occur, disclose and describe how the interim measures were found successful.

Also, NEPA requires full disclose and an evaluation of all factors involved in any decision. The USBR steps aside and states that "The restruction of the reservoir elevation is independent of the seismic corrective action proposed in this environmental assessment." The reservoir levels are part of the project and the sum total of the parts involved with the proposed project. There is sufficient case law hanging around to hang the USBR on that issue. We believe the restrictions and the lifting of the restructions is part of the proposed projects. Consequently, the restrictions and the lifting of the restrictions should be evaluated under all alternatives for the proposed project.

8. Disclose and describe the earthquake fault systems near and/or under Bradbury Dam, Include a map of the fault systems in the project area in the final EA. The public needs to know where the earthquake fault systems are located and what would be the effects to the failure of the dam from those existing fault systems.

9. The discussion under alternatives is deficient because with each alternative the draft EA should have disclosed and described the water supply options available to water users to keep the reservoir levels at and under 680 feet. i.e. Does the USBR protect reservoir levels at Cachuma Reservoir in the interim period and prior to completion of the proposed project or does the USBR protect the downstream areas from potential adverse public health and safety impacts.

10. We are having problems with the USBR's decision not to reduce reservoir levels to 680 feet or to the minimum pool to protect public health and safety in the downstream areas of the Santa Ynez River watershed. We are of the opinion that the USBR made a political decision in protecting the water supply as opposed to protecting public health and safety in the downstream areas below Bradbury Dam.

Disclose and describe in the final EA the specific reasons why water supply options were not evaluated under a reasonable range of alternatives to protect public health and safety in the downstream areas of the Santa Ynez River below Bradbury Dam.

11. At a recent major controversial dam safety problem associated with a potential earthquake, the Federal Energy Regulatory Commission ordered the Pacific Gas and Elecetric Company to reduce reservoir levels at Butt Valley Reservoir in Plumas County to the minimum pool to protect public health and safety in the downstream areas. Butt Valley Reservoir has a capacity of 49,900 acre-feet and the reservoir was drawdown to 2,909 acre-feet to protect public health and safety. The earthquake concerns was that the dam could fail in the event of an earthquake of a magnitude of 7.0 or greater. The California Division of Dam Safety supported the drawndown of the reservoir.

It appears there are double standards among two federal agencies. Disclose and describe in the final EA why the USBR made the decision not to drawdown the reservoir to minium pool to protect public health and safety in the downstream areas. Also, include water supply options available to the local water users in the event of reducing reservoir levels and the capacity in the reservoir.

12. The draft EA did not disclose and describe the "wall of water" which would be discharged (instant cfs) from Bradbury Dam in the event of an earthquake and dam failure. The final EA should disclose and descibe the "wall of water" discharged (instant cfs) from Bradbury Dam in the event of a dam failure at the following reservoir evalations: 680 feet, 720 feet, 733 feet, and 750 feet. The downstream public need to have this information, and it should be included in the final EA.

13. This is to advise you and the USBR, that the USBR is still in violation of state law (Fish and Game Section 5937) and federal law (Section 8 of the Reclamation Act) by failing to release water at all times to keep the steelhead and other public trust resources in good condition at all times in the Santa Ynez River below Bradbury Dam.

Disclose and describe this issue in the final EA.

14. This is also to advise you and the USBR that several years the USBR in cooperation with the California Department of Water Resources proposed to enlarge Bradbury Dam and also to conduct dam repair work. We are of the opinion that the reason that project was deleted by the USBR and DWR was because the CSPA filed a protest with the SWRCB against DWR's water right application requesting the SWRCB to enforce state law and require that water is released at all times to keep in good condition steelhead trout and other public trust resources below Bradbury Dam to the Pacific Ocean.

Fully knowing that dam repair work was needed, the USBR delayed protecting public health and safety in the downstream areas of the river for several years.

Disclose and describe in the final EA the proposed dam repair work several years ago and why the USBR delayed this public health and safety protection measure for several years.

That concludes the comments of the CSPA. Please address and include these comments in the Final EA, and please forward a copy of the Final EA to me at the address listed below.

Respectfully Submitted

_______________________________________________

Robert J. Baiocchi, Consultant

For: California Sportfishing Protection Alliance

P.O. Box 357

Quincy, CA 95971

Bus Tel: 916-283-1115 or 916-283-1007; Fax: 916-283-4999 or 916-283-5017

cc: Interested Parties