April 21, 2014 Sharon McHale, Project Manager U.S. Bureau of Reclamation, Planning Division 2800 Cottage Way Sacramento, CA 95825-1893 Sent via email to
[email protected] RE: Comments on Draft Feasibility Report for Upper San Joaquin River Basin Storage Investigation – Temperance Flat River Mile 274 Reservoir Dear Ms. McHale: On behalf of the Natural Resources Defense Council, the Bay Institute, California Sportfishing Protection Alliance, and Friends of the River, we are writing to provide comments on the draft feasibility report for the Upper San Joaquin River Basin Storage Investigation - Temperance Flat River Mile 274 Reservoir (“Investigation”). As discussed in detail below, the Investigation is significantly flawed, does not accurately analyze the economic or ecosystem cost and benefits of the proposed project, and fails to comply with federal guidelines for project evaluation. As such, we strongly recommend that the Bureau of Reclamation (“Reclamation”) withdraw the Investigation, and recirculate a valid draft feasibility study once these flaws are addressed. The Investigation evaluates a proposal for Reclamation to construct the Temperance Flat River Mile 274 Reservoir above Millerton Lake/Friant Dam to provide an additional 19-76 TAF of water downstream. Over the past 60 years, Reclamation has conducted a number of studies to assess the feasibility of expanding storage at Friant Dam, including raising Friant dam and adding another dam immediately upstream of Friant dam (e.g. Temperance Flat), and has yet to develop a feasible option.1 It is unclear what new information is available to overturn these previous decisions and spend federal and state funds on a project already deemed infeasible.