On July 31, 2013 the San Luis & Delta-Mendota Water Authority and Westlands Water District issued a letter to express significant concerns over the planned supplemental release of Trinity Reservoir water to the lower Klamath River in August and September 2013. The following is a summary of the comment topics covered in the letter. The full 33-page letter is available here.

 

Summary of comment topics on Draft Environmental Documents for Use of Trinity Reservoir Water to Make Supplemental Releases to the Lower Klamath River [EA-13-07-NCAO and FONSI 13-07 NCAO]

 

I. Reclamation Has No Authority To Make The Proposed Supplemental Releases

 

a. The Proposed Releases Would Violate The Trinity ROD And CVPIA Section 3406(b)(23)

 

b. The Proposed Releases Would Violate CVPIA Section 3411(a) And 43 U.S.C. Section 483

 

c. The Proposed Releases Are Contrary To Reclamation’s Contractual Obligations to Optimize Deliveries

 

 

II. The Draft EA’s Statement Of Purpose And Need Is Inadequate

 

III. The Draft EA’s Discussion Of Alternatives Considered But Eliminated From Further Consideration Is Inadequate

 

IV. Reclamation Must Prepare An Environmental Impact Statement To Comply With NEPA

 

a. The Proposed Action May Have A Significant Effect On Water And Power Resources

 

i. Impacts To CVP Water Supply Allocations

 

ii. Impacts To Hydropower Generation

 

iii. Impacts To Cold Water Pool Management

 

iv. Impacts To Recreational Activities In Trinity Lake

 

v. Impacts To Groundwater Resources

 

vi. Cumulative Impacts

 

b. The Proposed Action May Have A Significant Effect On Biological Resources

 

i. Impacts To Trinity River Salmon

 

ii. Impacts To The Yellow Legged Frog, Western Pond Turtle, And Lamprey

 

iii. Impacts To Central Valley Salmonids

 

iv. Impacts To Green Sturgeon

 

v. Impacts To Delta Smelt

 

vi. Impacts To Longfin Smelt

 

c. The Proposed Action May Have A Significant Effect On The Environment With Respect To Climate Change

 

d. The Draft EA Fails To Adequately Address Environmental Justice

 

e. The Proposed Action May Have Significant Effects Within the CVP Service Area South Of The Delta

 

i. Shortages Of CVP Water Cause Reliance On Inadequate Alternative Supplies That Carry Significant Costs And Adverse Environmental Impacts

 

ii. The Socioeconomic Consequences Of Reduced Water Supply

 

f. Air Quality And Land Use May Be Significantly Affected By The Proposed Action And Require Further Analysis

 

i. Air Quality

 

ii. Land Use

 

V. The Proposed Action May Affect Species Listed Under The Endangered Species Act, And ESA Consultation Is Required