Comments on the Draft EIS/EIR for the Yolo Bypass Salmon Habitat Restoration and Fish Passage Project


February 14, 2018

Ben Nelson
Bureau of Reclamation
801 I Street, Suite 140.
Sacramento, CA 95814

Via e-mail:

Re: Comments on the Draft EIS/EIR for the Yolo Bypass Salmon Habitat Restoration and Fish Passage Project

Dear Mr. Nelson:

I am writing to offer the following comments on behalf of the Golden Gate Salmon
Association, Pacific Coast Federation of Fishermen’s Associations, Institute for
Fisheries Resources, Coastside Fishing Club and Nor-Cal Guides and Sportsmen
Association regarding the DEIS/DEIR for the Yolo Bypass Salmon Habitat
Restoration and Fish Passage Project. Our organizations, which represent
commercial, recreational and other aspects of the salmon fishing industry, strongly
support a well-designed salmon fish habitat and passage project for the Yolo Bypass.
To this end, we strongly recommend the selection of a different preferred
alternative in the final document that would maximize benefits for Central Valley
salmon runs.

Preferred Alternative: The draft document states that Alternative 1 is “currently”
the preferred alternative (P. 2-17). Fortunately, this language suggests that the
selection of this alternative is not a final decision. Our organizations recommend
that Alternative 6 be selected as the preferred alternative, both because of its 12,000
cfs capacity and its selection of the west side of Fremont Weir for the location of the
primary intake facility. However, we believe that some features considered in other
alternatives should be considered for inclusion in a final preferred alternative based
on alternative 6. These issues are discussed in our specific comments below.

Specific Comments
Inadequate Focus on the Fall Run: The criteria for developing alternatives (Table
2-2) are focused on winter-run and spring-run Chinook, Central Valley steelhead
and green sturgeon. This focus is seen in many places in the document (e.g. Table 8-3).

In addition to this focus on listed species, it is important for the document to
reflect the fact that fall-run Chinook salmon could also benefit from a carefully
designed project. Given that some fall run characteristics, such its upstream
migration period and the details of its outmigration period, vary from those of some
listed species, we believe the final document should pay greater attention to the
needs of and potential benefits for the fall run. The need to add the fall run to the
criteria for selecting and evaluating alternatives is discussed below.

Additional State Mandates for Salmon Restoration: As the draft indicates (p. 8-
55), restoration of the fall run, specifically to double the naturally reproducing
population from 1967-1992, is required by the CVPIA. This doubling requirement is
also included in the State Board Bay-Delta Water Quality Control Plan and in Senate
Joint Resolution 19 (1983.) However, the discussion of state plans, policy and
regulations (Sec. 8.2.2) does not discuss either of these state doubling requirements.
Further, Senate Joint Resolution 7, passed in 2017, urges state agencies to make
“salmon fishery restoration an urgent and high priority.” In addition, the discussion
of relevant state plans, policy and regulations does not include the fisheries
responsibilities associated with the Public Trust or Section 5937 of the Fish and
Game Code. Together, these mandates require a more ambitious approach to
salmon restoration and to a greater focus on the fall-run. We recommend that all of
these additional salmon restoration mandates be included in the final document. As
a result of all of these obligations, GGSA believes that fall run should be listed on the
document’s criteria for developing and evaluating alternatives. We also believe that
these obligations suggest that the preferred alternative should reflect the
approaches with the greatest potential to benefit salmon.

Status of Central Valley Salmon Runs and the Salmon Fishery: The draft
includes a discussion of the fish species evaluated. That discussion includes all of
the salmonids in the Sacramento Valley. However, that section of the document
does not include a thorough discussion of the current status of all of these species.
That status is important, because it highlights the need for urgent and ambitious
action to maximize benefits for salmon from this project.

The California salmon fishing industry, as well as the coastal salmon fishery in
Oregon, rely overwhelmingly on Central Valley fish. As a result, the fishing industry
suffers significantly when Central Valley runs decline. Those runs, the fishing
industry, and fishing communities have suffered dramatic harm in the past decade.
The following are only a few examples of this decline.

• In 2008-2009, as a result of low adult populations, the California commercial
and recreational salmon fisheries were closed for the first time in state
history. This decision shut down an industry that, in recent previous years,
had generated 23,000 jobs and than $1.4 billion in annual economic activity.

• In 2017, as a result of low adult populations, commercial salmon fishermen
along the California coast lost 2/3 of the fishing season they had five years

• The California commercial salmon harvest has fallen more than 90 percent,
from nearly 800,000 fish a quarter century ago, to 56,000 fish in 2016. The
final numbers for the 2017 commercial harvest will be similarly poor.

• During 2014 and 2015, 95 to 98% of juvenile fall and winter run salmon
were killed in the Sacramento River as a result of poor water management.

• Sacramento River basin winter and spring run spawning adult populations
have reached dangerous lows in the past year.

The document should be revised to reflect recent trends in the populations of all
runs of salmon in the Sacramento Valley. This is important context that should be
considered in selecting the final preferred alternative.

Benefits of Larger Intake Capacity: GGSA supports the largest potential capacity
for the operable intake faculty for this project. Alternative 1, the current preferred
alternative, has a capacity of only 6,000 cfs, only half of the 12,000 cfs capacity of
Alternative 6.

The description of Alternative 6 clearly states the benefit of a larger intake capacity:
the large capacity in that alternative is intended to draw more fish and water into
the bypass (p. 2-64). Greater flows that would result from this alternative will
result in a greater area of inundation and greater food production. Perhaps most
importantly, a larger capacity can maximize the number of fish that benefit from
Yolo Bypass floodplain habitat. As a result, a 12,000 cfs capacity intake facility
offers the greatest potential benefits for listed and non-listed species in terms of the
number of fish that would receive benefits, increased growth rates and increased
survival to adulthood. A large capacity maximizes flexibility and maximizes
relatively natural floodplain habitat while retaining the potential benefits from
managed wetlands.

The document demonstrates that the potential benefits from a larger intake facility
are dramatically greater than the current preferred alternative. The following are a
few examples, excerpted from the draft.

Average Number of Juvenile Fall-Run Chinook Rearing in the Bypass for One or
More Days
(Difference between existing conditions and the alternative)

Alternative 1 Alternative 6
 Entire Simulation Period  1,574,215  2,676,043
 Above-Normal Years  2,557,474  4,217,227

Source: Tables 8-11, 8-40

Average Number of Fall-Run Chinook Adult Returns
(Difference between existing
conditions and the alternative)

Alternative 1 Alternative 6
 Entire Simulation Period 11,176 18,580
 Above-Normal Years 16,281 25,251

Source: Tables 8-8, 8-37


Average Monthly Wetted Area (Difference, in km2, between existing conditions and
the alternative)

Alternative 1 Alternative 6
 February – Entire Simulation Period 14.8 22.4
 February – Above-Normal Years 26.9 39.1

Source: Tables 8-7, 8-36


In summary, alternative 6 could produce up to 51% more floodplain habitat, benefit
up to 70% more juveniles and produce up to 66% more returning adults. These
compelling numbers clearly indicate that Alternative 6 should be the foundation for
the final preferred alternative.

Inundation Period: The alternatives included in the document primarily include
an inundation period that extends to March 15. However, alternative 4 provides for
ending the inundation period by March 7 or March 15 (Table 2-4.) We recommend
that the final preferred alternative include the longer inundation period, which
would increase benefits for spring and fall-run Chinook salmon. We also urge the
Bureau to consider an inundation period that extends beyond the end of March.
The spring-run salmon outmigration period extends until mid-May (p. 2-2), and the
fall run outmigration period extends into June. The operations of the operable gate
should match this outmigration period to the greatest extent possible. The
document should carefully justify any inundation period shorter than the full
outmigration period for all salmon runs.

The management of operable gates after the final inundation period is also
important. Specifically, we urge the Bureau to adopt an operations strategy that
allows for the use of the operable gates to extend brief flood events that overtop the
weir after the conclusion of the inundation period. This could extend the salmon
benefits of brief flood events late in the season. For example, should a natural flood
overtop the weir for a day or two in late March or early April, we urge an operations
plan that allows for the operable gates to be used to extend that inundation period
for a total of 10-14 days.

Location of Intake: The summary of alternative 6 suggests that the location of the
gate on the western portion of the weir would increase the number of fish entrained
into the Yolo bypass (P. 2-64.) Clearly, the size of the opening produces significantly
greater benefits for salmon. It also appears that a Western location would deliver
additional benefits. However, the draft does not clearly describe the benefits of
different gate locations. We recommend that the final document clearly discuss the
potential benefits produced by the location of the intake, as distinguished from
capacity. For example, the document does not include an evaluation of benefits
from a 12,000 cfs facility at locations different from that in Alternative 6. GGSA
recommends that the preferred alternative include the location, as well as the size,
that would provide the greatest benefits.

Integration of Gate Operations with Pulse Flows: GGSA believes that pulse flows
should be required on the Sacramento and Feather Rivers to increase the survival of
out-migrating juvenile salmon and believes that such flows may be required in the
future. The document should be revised to discuss the potential additional benefits
from integrating the operations of new operable gates in the Fremont Weir with
potential future spring pulse flows.

OCAP BO Mitigation Requirement: The document should include a clear analysis
of the relevant mitigation requirements in the OCAP BOs and the extent to which
alternatives would fully meet the floodplain habitat mitigation requirement.

Fish Passage Related to Additional Management Options: GGSA is supportive of
potential additional management actions that could provide additional benefits in
the bypass, including the use of managed wetland/rice field habitat to provide
additional rearing habitat, as well as berms to allow the inundation period in the
bypass to be extended. Both of these options offer the potential to provide
additional floodplain benefits in drier years. However, in both cases, it will be
essential to ensure that upstream and downstream fish passage is unimpaired and
that facilities related to these management options do not create predation hot
spots. We understand that there is a new propose facility design related to managed
wetlands that could reduce the potential for fish migration impacts. We look
forward to learning about that design, and reading the updated fish passage
analysis, in the final document.

Thank you for considering our comments.





John McManus Noah Oppenheim





Dick Pool Jeff Richards
Water4Fish Coastside Fishing Club





Jeff Richards
Water4Fish Coastside Fishing Club
President President





Noah Oppenheim
President Executive Director





James Stone
NorCal Guides and Sportsmen’s Associations