Lower Yuba Update
Subject: Lower Yuba River - Front Burner
Date: Fri, 03 Apr 1998 16:34:40 +0000
From: BOB BAIOCCHI <cspa@psln.com>
Organization: CSPA
To: CSPA Board of Directors, via email
CALIFORNIA SPORTFISHING PROTECTION ALLIANCE
P.O. BOX 357
QUINCY, CA 95971
BUS TEL: 530-836-1115
FAX: 530-836-2062
Ms. Carol L. Sampson, Director April 3, 1998
Office of Hydropower Licensing
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Chairman and Members of the
California State Water Resources Control Board
P.O. Box 100
Sacramento, CA 95812-0100
Mr. James Lecky, Chief
Protected Species
U.S. National Marine Fisheries Service
501 West Ocean Blvd. Suite 4200
Long Beach, CA 90802-4213
Mr. Wayne White, State Supervisor
U.S. Fish and Wildlife Service
3310 El Camino Avenue, Suite 130
Sacramento, CA 95821-6340
Ms. Jacqueline Schafer, Director
California Department of Fish and Game
1416 Ninth Street
Sacramento, CA 95814
Re: Lower Yuba River Project; FERC Project No. 2246; State of
California; Yuba County Water Agency, Licensee, Proposal by Yuba County
Water Agency to Adopt Mitigated Negative Declaration; Proposed Changes
in Operations of New Bullards Bar Reservoir; Proposed Bay-Delta
Settlement Agreement; Yuba River, Tributary to Sacramento River thence
San Francisco Bay-Delta; Comments and Formal Request for Relief by
California Sportfishing Protection Alliance.
Dear Ms. Sampson, Ms. Schafer, Mr. Lecky, Mr. White, and Members of the
California State Water Resources Control Board:
The California Sportfishing Protection Alliance hereby submit the
following comments and formal request for state and federal regulatory
relief:
The California Sportfishing Protection Alliance (CSPA) has reviewed the
Yuba County Water Agency's (YCWA) Notice of Proposal to Adopt Mitigated
Negative Declaration for proposed changes to the operations of New
Bullards Bar Reservoir (FERC Project No. 2246) in conjunction with the
not yet approved Bay-Delta Settlement Agreement between YCWA, California
Department of Water Resources, and the U.S. Bureau of Reclamation. The
following are the comments of the CSPA:
1. The Negative Declaration is premature and deficient as shown below.
YCWA has failed to file a petition with the California State Water
Resources Control Board (CSWRCB) for the proposed long term water
transfer pursuant to Section 1735 et seq. of the California Water Code,
subject to formal protests by interested parties such as CSPA, and also
subject to a hearing before the CSWRCB.
The CSWRCB should require YCWA to file a petition for a long term water
transfer pursuant to the provisions of the California Water Code.
2. The Initial Study and Negative Declaration are grossly deficient. The
mitigation measures in the initial study and in the negative declaration
failed to comply with the flow recommendations and testimony by the
California Department of Fish and Game before the CSWRCB concerning the
California Department of Fish and Game's (CDFG) Lower Yuba River Fishery
Management Plan in CSPA et al. v. YCWA et al. (Complaint - Hearing
1992).
Based on the flow recommendations and the testimony of the CDFG at the
hearing before the CSWRCB in 1992 in CSPA et al. v. YCWA et al., any
daily flows less than those recommended by the CDFG in their management
plan for the Lower Yuba River would violate California Fish and Game
Code 5937 (and Section 782, California Code of Regulations, Title 23).
Consequently, the proposed project will have adverse direct, indirect,
and cumulative impacts to the threatened anadromous fisheries of the
Lower Yuba River, and an EIR must be prepared for the proposed project.
The lead agency under CEQA should be the CSWRCB and not the YCWA because
the YCWA cannot make an impartial determination regarding the direct,
indirect, and cumulative effects to threatened steelhead trout, fall-run
and spring-run chinook salmon species and their habitat of the Lower
Yuba River.
The CSWRCB should prepare an Environmental Impact Report pursuant to
the requirements of the California Environmental Quality Act and its
Guidelines for the proposed project because of direct, indirect, and
cumulative adverse impacts to the threatened anadromous fisheies of the
Lower Yuba River as testified to by the CDFG at the hearing of 1992
before the CSWRCB.
3. The present operation of New Bullards Bar Reservoir (FERC Project No.
2246) by YCWA is in violation of California Fish and Game Code 5937 and
Section 782, California Code of Regulations, Title 23, as stated in
testimony by the CDFG because YCWA has failed to comply with the daily
flow recommendations of the CDFG in their Lower Yuba River Fishery
Management Plan.
The CSWRCB and the California Department of Fish and Game must bring
YCWA into full compliance with state law to protect the threatened
steelhead, fall-run and spring-run chinook salmon fisheries of the Lower
Yuba River.
4. The Lower Yuba River sustains steelhead trout and their habitat.
Steelhead trout of the Central Valley have been listed for protection as
threatened by the U.S. National Marine Fisheries Service (USNMFS) under
the provisions of the federal Endangered Species Act (ESA). The proposed
project will jeopardize steelhead and their habitat based on the flow
recommendations in the CDFG's Lower Yuba River Fishery Management Plan,
including the oral testimony of expert witnesses by the CDFG before the
CSWRCB.
YCWA must consult with the USNMFS pursuant to Section 7 of the federal
ESA to determine and mitigate the adverse effects to Yuba River
steelhead trout resulting from the proposed project operational changes,
and also resulting from the 1965 flow Agreement.
The CSPA believes that the USNMFS and the Federal Energy Regulatory
Commission (FERC) must require YCWA to comply with the CDFG's Lower Yuba
River Fishery Management Plan in order to avoid jeopardy to steelhead
trout and their habitat in the Lower Yuba River resulting from the
existing operation and proposed operational changes of New Bullards Bar
Reservoir (FERC Project No. 2246).
5. The USNMFS is proposing to list fall-run, late-fall-run, and
spring-run chinook salmon in the Central Valley of California. The Yuba
River is part of the Central Valley of California and sustains fall-run
and spring-run chinook salmon, and may sustain late-fall chinook salmon.
The CSPA believes that the FERC, CSWRCB and USNMFS must require YCWA to
comply with the CDFG's Lower Yuba River Fisheries Management Plan in
order to avoid jeopardy to fall-run and spring-run chinook salmon and
their habitat in the Lower Yuba River resulting from the operation of
the existing project, and also resulting from proposed major changes to
the existing operation of FERC Project No. 2246.
6. The proposed settlement agreement involves YCWA, California
Department of Water Resources (CDWR), and the U.S. Bureau of Reclamation
(USBR), a federal agency, which are all water diverters. The not yet
approved settlement agreement also involves state and federal water
projects, of which two of the projects operate under federal licenses
issued by the FERC. New Bullards Bar Reservoir (FERC Project No. 2246 -
Lower Yuba River) operates under a federal FERC license, Oroville
Reservoir (FERC Project No. 2100 - Feather River) operates under a FERC
license, and the State Water Pumps (California Aqueduct) operates under
a FERC license. The Central Valley Project is a federally owned and
operated project which is operated by a federal agency (USBR) pursuant
to federal law.
The initial study and negative declaration are grossly deficient
because the documents were not prepared pursuant to the federal NEPA and
its requirements. A combined federal NEPA document and CEQA document for
the proposed changes in operations, and also the not yet approved
settlement agreement should be prepared because two projects operate
under federal licenses (FERC Project Nos. 2246 and 2100), and one
federal project (CVP) operates pursuant to federal law. Under NEPA, the
lead agency should be FERC because of the change of operations at two
FERC licensed projects.
7. The proposed project involves major change in operations related to
the quality and quantity of water in New Bullards Bar Reservoir (FERC
Project No. 2246), which operates under a FERC license. The CSPA
believes YCWA is required to file an amendment to its FERC licenses with
the FERC for said changes in operations for FERC Project No. 2246, and
also because the existing operations and the proposed operational
changes will adversely impact threatened Yuba River steelhead trout
protected under the provisions of the federal Endangered Species Act as
well as impact Yuba River fall-run and spring-run chinook salmon being
proposed for listing under the protection of the provisions of the
federal Endangered Species Act.
8. The CSWRCB has Section 401 of the Clean Water Act authority at FERC
licensed projects in California. YCWA also operates under water right
permits issued by the CSWRCB. Clearly, the CSWRCB has the authority
under its water rights and public trust authority, as well as its
Section 401 CWA authority, to require that changes in the operations of
New Bullards Bar Reservoir do not damage or harm the beneficial uses of
the state's water.
The CSWRCB must use its Section 401 CWA authority, and also its water
rights and public trust authority to protect the beneficial uses of the
state's water in the Lower Yuba River effected by the operations of the
existing project as well as the proposed operational changes of New
Bullards Bar Reservoir. The existing flow requirements in the 1965
Agreement adversely effect cold water fish species of the Lower Yuba
River as clearly shown in the CDFG Lower Yuba River Fishery Management
Plan, and also as clearly stated in oral testimony by the CDFG before
the CSWRCB at the hearing in 1992. i.e. see flow and water temperatures
requirements in said CDFG fisheries management plan.
9. The U.S. Fish and Wildlife Service (USFWS) has a duty to protect
anadromous fisheries at FERC licensed projects. The USFWS must petition
the FERC and require the license for FERC Project No. 2246 is re-opened
and modified to protect threatened steelhead, fall-run and spring-run
chinook salmon, including American shad species and their habitat in the
Lower Yuba River. The USFWS should include in their petition to FERC the
flow and water temperature recommendations in the CDFG Lower Yuba River
Fishery Management Plan, including other recommendations.
10. The CDFG Lower Yuba River Fishery Management Plan was based on a
three year study authorized and paid for under California Assembly Bill
723 (1985), Section 10000 of the California Public Resources Code. The
bill directed CDFG to do the necessary studies to determine what
streamflows are necessary for fishery protection and to transmit those
findings to the CSWRCB. Study costs were about $256,000. The general
conclusion based on the study was that the existing streamflows
contained in the 1965 Agreement between CDFG and YCWA were inadequate to
sustain the anadromous fishery in good condition.
The CDFG, as a state trustee agency, has a duty to protect anadromous
fisheries at FERC licensed projects in California. The CDFG must
petition the FERC and require the license for FERC Project No. 2246 is
re-opened and modified to protect threatened steelhead, fall-run and
spring-run chinook salmon, including American shad species and their
habitat, and water quality in the Lower Yuba River. The CDFG should
include in their petition to FERC several copies of the CDFG Lower Yuba
River Fishery Management Plan.
11. According to the YCWA notice, up to 19,000 acre-feet of water would
be released from New Bullards Bar Reservoir (FERC Project No. 2246)
during dry and critically dry water years for use by either the State
Water Project (CDWR) and/or the Central Valley Project (USBR) to meet
their environmental and contractual obligations, plus any forthcoming
water transfers and exporting of Yuba River water by YCWA that are not
related to the protection of water quality and the fisheries of the
Bay-Delta. The water (19,000 af) would either be allowed to flow into
the Bay-Delta, where it would be exported using a FERC licensed project
or used to implement Bay-Delta water quality, or stored (by exchange) in
Lake Oroville (FERC Project No. 2100) or Shasta Lake (USBR) for eventual
use in SWP (DWR) or CVP (USBR) operations. As stated beforehand, the
State Water Pumps, which exports water from the Bay-Delta (California
Aqueduct), also operates under a FERC license.
Water stored in New Bullards Bar Reservoir is critical for steelhead
trout and chinook salmon to survive because reduction in the contents of
cold water at the reservoir could jeopardize and extinguish Yuba River
threatened steelhead trout and fall-run and spring-run chinook salmon
species in the short and long term future under the proposed changes to
operations at FERC Project No. 2246, and also the not yet approved
settlement agreement.
The purpose of the project is to provide for releases of water that
would satisfy the obligations of Yuba River water right holders (YCWA)
to contribute to implementing the objectives of the CSWRCB's 1995 Water
Quality Control Plan. The CSPA disagrees with the above conclusion.
Even during the recent drought, YCWA had large quantities of water to
sell and transfer to the California Drought Emergency Water Bank. i.e.
1987 - 83,100 af; 1988 - 122,000 af; 1989 - 246,000 af; 1990 - 116,000
af and 1991 - 157,000 af. The proposed 19,000 af of water represents a
small portion of the water that was sold by YCWA during the recent
drought.
The CSPA believes that the FERC and the CSWRCB should order YCWA to
implement the CDFG's Lower Yuba River Fishery Management Plan flows and
water temperature requirements in order for water rights holders (YCWA)
on the Lower Yuba River to satisfy their combined obligations and public
trust duties to protect the threatened anadromous fisheries of the Yuba
River affected by FERC licensed Project No. 2246, and also to provide
water into the San Francisco Bay-Delta for fisheries and water quality
protection during all water year types which includes dry and critically
dry water years. That would be reasonable and in the public interest
since the water belongs to the people of the State of California, and
the fish and wildlife resources are the property of the people of the
State of California, and are public trust assets.
12. The YCWA failed to provide the CSPA with a timely copy of their
public notice for the proposed project, and also after formal
notification by CSPA, failed to provide the CSPA with timely copies of
the initial study and negative declaration for the proposed project.
YCWA acted in bad faith in failing to submit its public notice, initial
study, and negative declaration to parties such as the CSPA involved in
the CSWRCB 1992 Lower Yuba River hearing.
The CSWRCB should investigate and determine the parties that did
receive timely copies of the YCWA notice, initial study, and negative
declaration, because it involves a long term water transfer affecting
the public trust resources and assets of the Lower Yuba River and the
San Francisco Bay Delta.
13. Any and all actions taken by the federal and state agencies for the
proposed project and the not yet approved settlement agreement must be
in full compliance with all applicable federal and state statutes and
regulations.
The California Sportfishing Protection Alliance is requesting formal
actions and relief by the state and federal agencies as shown above to
protect the threatened steelhead trout, fall-run, and spring-run chinook
salmon of the Lower Yuba River.
Please advise me of your individual decisions in this matter in
writing. Thank you for your time and interest in this important matter
to California andromous fisheries in the Lower Yuba River.
Respectfully Submitted
_______________________________________________
Robert J. Baiocchi, Consultant
For: California Sportfishing Protection Alliance
P.O. Box 357
Quincy, CA 95971
attachment - YCWA Notice
Also see attached reference
Lower Yuba River Streamflow Issues
A History and Summary of Issues
I. History of Recent Events Concerning Streamflow Issues in the Lower
Yuba River
February 23, 1988 - Original Complaint filed with the State Water
Resources Control Board (CSWRCB) by coalition of fishery groups
including the California Sportfishing Protection Alliance (CSPA) and
South Yuba River Citizens League (SYRCL).
Main contention of complaint is that the minimum streamflow
requirements specified in the Yuba County Water Agency's (YCWA) existing
water right permits and 1965 Agreement do not provide an adequate level
of protection for anadromous fish in the Lower Yuba River.
May 8, 1991 - The California Department of Fish and Game (CDFG) requests
the CSWRCB to revise existing streamflow and water temperature
requirements for the Lower Yuba River.
CDFG request was based on a three year study authorized and paid for
under California Assembly Bill 723 (1985), Section 10000 of the
California Public Resources Code. The bill directed CDFG to do the
necessary studies to determine what streamflows are necessary for
fishery protection and to transmit those findings to the CSWRCB. Study
costs were about $256,000. The general conclusion based on the study was
that the existing streamflows contained in the 1965 Agreement between
CDFG and YCWA were inadequate to sustain the anadromous fishery in good
condition.
February 10. 1992 to June 8, 1992 - The CSWRCB held a hearing to
consider fishery recommendations proposed by CDFG, the U.S. Fish and
Wildlife Service (USFWS) and the coalition of fishery groups, which
included the CSPA.
Ten (10) to fifteen (15) thousand pages of testimony were presented by
fifteen (15) parties during the fourteen day hearing. Major contributors
were YCWA, Cordua Irrigation District, South Yuba Water District, CDFG,
USFWS, CSPA and SYRCL. The water districts argued for the status quo.
The USFWS and the coalition of fishery groups supported CDFG's request
for increased streamflows and lower water temperatures.
Late in 1993 - The CSWRCB's staff analysis of the hearing record was
completed and a draft decision submitted to the members of the CSWRCB
for discussion and approval.
The members of the CSWRCB have had that report for about four (4) plus
years and has yet to take action.
Spring of 1996 - The CSPA sends letter to the CSWRCB asking that they
make a decision but the CSWRCB ignores request.
To date no other party to the hearing has urged the CSWRCB to take
action. i.e. CDFG. The CDFG, after investing $256,000 in the Lower Yuba
River Fishery Study and Management Plan and nearly three (3) man years
of time in supervising the contracted study, analyzing the data, writing
the management plan, and participating in the CSWRCB hearing, has not
file a petition, filed a lawsuit, or put any pressure on the CSWRCB to
make a decision.
II. Fishery Issues in the Lower Yuba River
The 1965 Agreement Streamflows -
Normal and Above normal water years below Daguerre at Smartsville:
January 1 - June 30...............245 cfs
July 1 - September 30............. 70 cfs
October 1 - December 31...........400 cfs
Average unimpaired streamflows upstream of Daguerre at Smartsville:
January 1 - June 30...............5383 cfs
July 1 - September 30............. 538
October 1 - December 31...........1719 cfs
Native Species of Lower Yuba River - Steelhead trout, fall-run chinook
salmon, and spring-run chinook salmon.
Steelhead Trout - Recently listed as threatened by the U.S. National
Marine Fisheries Service. A population of naturally reproducing
steelhead exists in the Lower Yuba River. Spawning and rearing can occur
throughout the Lower Yuba River. CDFG's study shows that water
temperatures for incubation of eggs in the spring are not adequate under
existing streamflows.
Fall-Run Chinook Salmon - Recently proposed for listing by the U.S.
National Marine Fisheries Service for protection under the provisions of
the federal ESA. An annual average of 13,000 fall-run adults spawn in
the Lower Yuba River. No hatcheries exist on the Lower Yuba River so
these fish are primarily from natural reproduction. CDFG's study shows
that streamflows under the 1965 Agreement are not adequate for
attraction, spawning, rearing, and outmigration. CDFG's study also shows
that water temperatures for spawning in the fall and for rearing in the
spring are not adequate under existing streamflows.
Spring-run Chinook Salmon - Recently proposed for listing by the U.S.
National Marine Fisheries Service for protection under the provisions of
the federal ESA. Also, proposed for listing by the California Fish and
Game Commission under the protection of the state ESA. A remnant
population of spring-run exists in the Lower Yuba River. Adults summer
over in the Narrows just downstream of Englebright Dam and spawn just
downstream of the Narrows. CDFG's study shows that water temperatures
for spawning in the fall and for rearing in the spring are not adequate
under existing project operation and streamflows.
American Shad - American shad are a non-native fish and were introduced
into the Bay Delta by the CDFG in about 1890. American shad fishing in
the Lower Yuba River, Feather River, and the Sacramento River are very
popular among California licensed anglers. American shad species and
their habitat was studied and protected under the CDFG Lower Yuba River
Fishery Management Plan based on flow recommendations for American shad
(all life stages).
Fish Screens - Three major irrigation diversions are located upstream of
Daguerre Point Dam: The Browns Valley Diversion, the South Yuba/Brophy
Water District's South Canal and the Hallwood, Cordua and Ramirez
District's North Canal. Water diversion occur primarily from March
through October.
The Browns Valley Diversion (80 cfs) is unscreened.
South Yuba/Brophy Water District's South canal (380 cfs to 700 cfs)
uses a rock levee for a screen. This screen device is not approved by
either CDFG or the USFWS.
Hallwood, Cordua and Ramirez District's North Canal (625 cfs) has an in
canal perforated plate screen constructed, operated, and maintained by
CDFG. The screen does not meet CDFG's minimum standards and it is only
operational in the spring during years when river flow is low.
Therefore, outmigrating threatened steelhead and chinook salmon are
entrapped and harmed during the summer and fall.
YCWA (FERC Licensee) has water contracts and provide water from New
Bullards Bar Reservoir (FERC Project No. 2246) for said diversions from
the Lower Yuba River as shown above, which are having adverse harm and
impacts to threatened steelhead and fall-run and spring-run chinok
salmon species.
III. State of California Salmon, Steelhead Trout and Anadromous
Fisheries Program Act
In 1988, the California Legislature passed the Salmon, Steelhead Trout
and Anadromous Fisheries Program Act (California Fish and Game Code
Section 6902). The Act emphasizes the importance of protecting and
increasing the number of natural reproducing salmon and steelhead in the
State of California. The Act establishes that it is State policy to: (1)
significantly increase natural production and (2) prevent the further
loss of habitat without offsetting the impacts of the lost habitat.
Both the CSWRCB and CDFG are in violation of the 1988 State policy. The
natural production of steehead and salmon throughout the State is in
significant decline due mostly to water diversions approved by the
CSWRCB. Steelhead trout of the Central Valley of California were
recently listed as threatened by the U.S. National Marine Fisheries
Service under the protection of the provisions of the federal Endangered
Species Act. Spring-run and fall-run chinook salmon are also being
proposed for listing by the U.S. National Marine Fisheries Service under
the protection of the federal Endangered Species Act as well as
spring-run chinook salmon under the State Endangered Species Act.
The Yuba River is one of the few triburaries in the Sacramento River
system where steelhead and salmon reproduce naturally. The CSWRCB had
the opportunity to protect Yuba River steelhead and salmon habitat from
diminishing further but has failed to act on a hearing record for the
past six (6) years to protect the federally threatened steelhead and
fall-run and spring-run chinook salmon species of the Lower Yuba River.
The CDFG, after spending $256,000 and nearly three (3) man years of
time in developing the Lower Yuba River Fishery Study and Management
Plan, has been unwilling to file a petition with the CSWRCB or file a
lawsuit against the CSWRCB for violation of California Fish and Game
Code 5937 to bring YCWA into compliance with the CDFG's Lower Yuba River
Fishery Management Plan flow and water temperature recomendations to
protect the threatened steelhead, and fall-run and spring-run species of
the Lower Yuba River watershed.
It strongly appears the only answer to remedy the significant adverse
impacts to threatened anadromous fishery problems on the Lower Yuba
River resulting from the existing and proposed operations of FERC
Project No. 2246 is responsible federal regulatory actions by the
Federal Energy Regulatory Commission, the U.S. National Marine Fisheries
Service, and the U.S. Fish and Wildlife Service. The CSPA is requesting
formal actions by those federal regulatory agencies.
California Sportfishing Protection Alliance
Bob Baiocchi - 4/98
Service List
Honorable State Senator Tom Hayden
California Legislature
State Capitol - Room 2080
Sacramento, CA 95814
Honorable State Senator Byron Sher
California Legislature
State Capitol - Room 2054
Sacramento, CA 95814
Mr. David Boergers, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
(7 Copies and Original)
Ms. Carol L. Sampson, Director
Office of Hydropower Licensing
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Mr. Noel Folsom, Regional Director
Federal Energy Regulatory Commission
901 Market Street, Suite 350
San Francisco, CA 94103
California State Water Resources Control Board
Chairman and Members
P.O. Box 100
Sacramento, CA 95812-0100
Ms. Jacqueline Schafer, Director
California Department of Fish and Game
1416 Ninth Street
Sacramento, CA 95814
Ms. Nancee Murray, Esquire
Legal Affairs Division
California Department of Fish and Game
1416 Ninth Street
Sacramento, CA 95814
Mr. Steve Volker, Esquire
Earthjustice Legal Defense Fund
180 Montgomery Street, Suite 1725
San Francisco, CA 94104-4209
Mr. Wayne White, State Supervisor
U.S. Fish and Wildlife Service
3310 El Camino Avenue, Suite 130
Sacramento, CA 95821-6340
Mr. James Lecky, Chief
Protected Species
U.S. National Marine Fisheries Service
501 West Ocean Blvd. Suite 4200
Long Beach, CA 90802-4213
Mr. Jim Bybee, Supervisor
U.S. National Marine Fisheries Service
777 Sonoma Avenue
Santa Rosa, CA 95404
Mr. Richard Roos-Collins, Esquire
Counsel for California Hydro Reform Coalition
NHI
114 Sansome Street
San Francisco, CA 94104
Mr. John Gangemi, Conservation Director
American Whitewater Affiliation
782 Swan River Road
Bigfork, MT 59911
Ms. Maureen Rose, Representative
Friends of the River
128 J Street, 2nd Floor
Sacramento, CA 95814
Ms. Johanna Thomas, Representative
California Hydro Reform Coalition
128 J Street
Sacramento, CA 95814
Mr. Jim Crenshaw, President
California Sportfishing Protection Alliance
1248 East Oak Street, Suite D
Woodland CA 95695
Mr. Mike Fitzwater, Member
California Sportfishing Protection Alliance
California Hydro Reform Coalition
2730 Third Avenue
Sacramento, CA 95818
Donn A. Wilson
Agency Engineer - Administrator
Yuba County Water Agency, FERC Licensee
1402 D Street - Marysville, CA 95901
Mr. Roger Patterson, Regional Director
U.S. Bureau of Reclamation
2800 Cottage Way
Sacramento, CA 95825
Mr. David Kennedy, Director
California Department of Water Resources, FERC Licensee
1416 Ninth Street
Sacramento, CA 95971
Interested Parties (Numerous)