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Pacheco Correspondence

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Pacheco Correspondence From: Katja Irvin To: California Water Commission Cc: Kyle Jones; Barbara Kelsey Subject: Re: Sierra Club - Pacheco Reservoir Date: Thursday, April 26, 2018 4:22:06 PM Attachments: Sierra Club Loma Prieta Chapter - Pacheco 1.pdf 041018 SCVWD Agenda Item 5-1.pdf Dear Commissioners and Staff, This letter is an update/addendum to our previous comments (attached below) about the Pacheco Reservoir project and funding application. Please forward all of these comments to the Commission for the meeting on May 1, 2018. The Sierra Club Loma Prieta Chapter still has many concerns about the project to build this huge new dam on Pacheco Creek. We are opposed to new or expanded on-stream reservoirs, and in this case it isn’t clear the project really is needed. Our understanding is that Santa Clara Valley Water District (District) modelling shows benefits will accrue mostly 50 years in the future. This is absurd since everything will have changed by then so the reliability of these predictions is questionable. We think it is wiser to look at nearer term benefits to evaluate the need for this project at this time. The latest analysis for the District’s 2017 Water Supply Master Plan (April 10, 2018 Staff Report, attached) explains that other District projects are sufficient to meet water supply level of service goals, based on model runs conducted over 94 years of hydrology. On October 17, 2017, the Board conditionally approved participation in California WaterFix, with the goal of offsetting a reduction of about 41,000 AFY of Delta- conveyed imported water supplies. On December 12, 2017, the Board also approved pursuing a public-private partnership to develop up to 24,000 AFY of potable reuse capacity using the Los Gatos Ponds. Staff analyzed the effect of these Board-approved projects, along with additional recharge in the Llagas Groundwater Subbasin that groundwater modeling indicates is needed to meet future demands, on water supply reliability. As shown in Table 1, the projects that are approved for planning are sufficient to achieve the interim water supply reliability level of service goal of meeting 100 percent of demands in normal years and at least 85 percent of demands in drought years. So the District’s own planning process currently underway doesn’t conclude that this huge new reservoir is needed in the foreseeable future. Twenty years ago the District’s Board decided not to pursue a dam project on Pacheco Creek and at the time they expressed a belief that no new dams would ever be built in Santa Clara County. Twenty years in the future, who knows what the Board’s position will be, but they will know a lot more about the impacts of climate change, population growth, and the effectiveness of many other water supply projects the District is currently undertaking. Therefore we feel the need to say again that the timing isn’t right for this project and there is a real risk that Santa Clara County ratepayers will be paying for a $1-2 billion stranded asset. Thank you for your consideration. Sincerely, Katja Irvin Conservation Committee Co-Chair Sierra Club Loma Prieta Chapter ----- Forwarded Message ----- From: Katja Irvin <[email protected]> To: "[email protected]" <[email protected]> Cc: Kyle Jones <[email protected]>; Mike Ferreira <[email protected]> Sent: Wednesday, January 31, 2018 4:16 PM Subject: Sierra Club - Pacheco Reservoir WSIP application comments Dear CWC Staff, The Sierra Club’s comments on the Pacheco Reservoir Expansion Project WSIP Application are attached. Please also forward these comments to staff, since we believe they will be very useful for any upcoming analysis or evaluation of this Application. Also, we can provide more background information if there are any questions or need specific references. Sincerely, Katja Irvin, AICP Sierra Club Loma Prieta Chapter Conservation Committee Sierra Club Loma Prieta Chapter Serving San Mateo, Santa Clara and San Benito Counties Protecting Our Planet Since 1933 3921 East Bayshore Road, Suite 204 Palo Alto, CA 94303 January 31, 2018 Armando Quintero, Chair California Water Commission 1416 Ninth Street Sacramento, CA 95814 RE: Pacheco Reservoir Expansion Project WSIP Application Dear Chair Quintero and Commissioner Members, The Sierra Club’s comments on the Pacheco Reservoir Expansion Project WSIP Application are attached. Although these comments were not submitted earlier in the application evaluation process, we feel it is important to submit our comments because we are closely following water supply planning processes at the Santa Clara Valley Water District (SCVWD). There have been many other comments sent to the Commission about this project but none have been sent by stakeholders who have been following the SCVWD 2017 Water Supply Master Plan update process. The Sierra Club Loma Prieta Chapter Conservation Committee has been studying and commenting on how SCVWD does water supply planning since the 2015 Urban Water Management Plan was under development. Therefore we hope that you read the attached comments despite our relatively late submittal. These comments are based on considerable research and contain a lot of information that is not easily available elsewhere. Please also forward these comments to staff, since we believe they will be very useful for any upcoming analysis or evaluation of this Application. Also, we can provide more background information if there are any questions or need specific references. Respectfully submitted, Katja Irvin, AICP Sierra Club Loma Prieta Chapter Conservation Committee Cc: Kyle Jones, Sierra Club California, Policy Advocate Mike Ferreira, Sierra Club Loma Prieta Chapter, Conservation Committee Chair Sierra Club Loma Prieta Chapter Serving San Mateo, Santa Clara and San Benito Counties Protecting Our Planet Since 1933 3921 East Bayshore Road, Suite 204 Palo Alto, CA 94303 Pacheco Reservoir Expansion Project WSIP Application Comments January 31, 2018 The Sierra Club has many concerns about the Pacheco Reservoir Expansion Project (Project). We see the Project as a new dam rather than an expansion of the existing reservoir. Specifically, this project cannot be compared to the expansion of Los Vaqueros Reservoir, mainly because this is an on-stream reservoir on the relatively pristine Pacheco Creek. This project will have significant environmental impacts that will need to be mitigated. We are concerned that the public benefits paid for by Water Supply and Infrastructure Program (WSIP) will be required as mitigations anyway, thereby offsetting the cost of water supply benefits (the main goal of the Project). Below we offer more detail about our concerns related to public benefits, followed by general concerns about project feasibility in the context of water supply planning for Santa Clara County. Public Benefits Ecosystem Improvement The Sierra Club is concerned about the viability of the ecosystem improvement proposed as part of the Project for several reasons. Water for South of Delta Refuges 1. The District Act which outlines Santa Clara Valley Water District (District) authorities may not include increasing water supplies for wetlands outside of Santa Clara County. The District can “dispose of, outside the district, any waters not needed for beneficial uses within the district.” We see a contradiction if the District gives away 2,000 acre feet per year of Santa Clara County’s imported water supply, supposedly not needed for beneficial uses, and at the same time claims the need for a new reservoir for additional water supply. 2. We question whether providing water to south of Delta refuges benefits the Delta. With the priority given to municipal and industrial supplies, this benefit is unlikely to hold up under drought conditions unless strong water rights are allocated to secure this environmental benefit. 1 Flow regimes and habitat for Salmonids 1. The Sierra Club is concerned that flow targets are unrealistic given the water supply goals of the Project. According to the Pacheco Reservoir Expansion Project Initial Study, average monthly release targets to Pacheco Creek for South-Central California Coast steelhead amount to more than 9,500 AF/year, while the natural hydrology of the North Fork Pacheco Creek watershed yields an average of 13,000 AF/year. The proposed fish operation scenario does not seem realistic since the District also plans to get 6,000 AF/year in additional water supply according to water supply planning documents (20,000 AF/year in dry years according to the District’s December 2017 presentation to the Commission). See section 1.5 of the Initial Study for proposed flow regime; http://valleywater.org/uploadedFiles/Newsroom/PublicReviewDocuments/Pacheco%20 Reservoir%20Project%20Initial%20Study%20Draft_Final_8-7- 17_SCH%20Copy.pdf?n=6069. 2. The Sierra Club is concerned about the Districts ability to deliver habitat improvements for steelhead in a timely manner. In 1996, a water rights complaint was filed at the State Water Resources Control Board indicating that District water supply operations in Coyote Creek, Guadalupe River, and Stevens Creek impact steelhead trout and Chinook salmon. To address the complaint and Endangered Species Act (ESA) issues, the District, Guadalupe Coyote Resource Conservation District, Trout Unlimited, the California Department of Fish and Wildlife, U.S. Fish and Wildlife Service, and National Marine Fisheries Service (NMFS), participated in the Fisheries and Aquatic Habitat Collaborative Effort (FAHCE) to develop a Settlement Agreement. The Settlement Agreement was initialed in 2003. A key Settlement Agreement provision is the Fish Habitat Restoration Plan, which proposes changes in reservoir releases, channel enhancements, monitoring and adaptive management. The Restoration Plan is part of Phase 1, to be completed by 2013. However, the District has yet to complete the Plan or release a Draft Environmental Impact Report (EIR) for FAHCE. No reservoir releases have been established for environmental public trust benefits. We are concerned that similar delays will occur with the claimed fisheries benefits on Pacheco Creek.
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