[env-trinity] What I said last night at the Bucktail/Lower Junction City channel restoration meeting

[Tom Stokely]

I said this and more at a meeting in Weaverville last night.

Somebody (not me, amazingly enough) made copies of the Draft Phase 1 review by the Science Advisory Board and left them on the table for people to obtain, so I guess the cat is out of the bag on that report...

There were also copies of a letter from the California Advisory Committee on Salmon and Steelhead regarding this issue sitting on the table, so I've attached a copy of that document for your information.    
 
Tom Stokely
Water Policy Analyst/Media Contact
California Water Impact Network
V/FAX 530-926-9727
Cell 530-524-0315
tstokely at att.net
http://www.c-win.org


My name is Tom Stokely.  I work for the California Water Impact
Network.  
 
The environmental
documentation for these projects is inadequate.  Preparation of an EIS/EIR is required for the following reasons:
 
The environmental documents
do not include an alternative that would decrease fine sediment reduction in
watersheds to improve mainstem and tributary habitat as identified in the
Trinity ROD.  Clearly such an alternative
is warranted since it too would increase juvenile salmonid habitat- a primary
TRRP goal and it is part of the ROD.  Upslope watershed restoration would also keep the sediment on tributary
slopes from moving into the mainstem Trinity River where they can cause
flooding and impact fish habitat, meeting project purpose and need.  
 
The purpose and need would
clearly allow this alternative to be evaluated but it is not.  The Master EIR previously prepared also lacks
an alternative that would accelerate underfunded watershed restoration activities
authorized through the Trinity ROD.  
 
You may not recall but when
the ROD was being litigated a decade ago, the federal district court judge
issued an injunction based on his view that inadequate attention was being paid
to alternatives that would restore tributaries, including the South Fork as a
means of meeting fishery restoration goals.  The Ninth Circuit later overturned that decision based on the fact that
the Trinity ROD included a watershed restoration component.  However, since that watershed restoration
component is not being carried out to the extent envisioned in the Trinity ROD,
it is again a viable legal argument against these projects.  A reasonable range of alternatives has not
been provided.
 
There are also significant
unmitigated impacts from past projects and presumably future projects such as: 
 
1.   boat launching
access has been reduced
2.   favorite holes
have filled in with gravel
3.   favorite adult
steelhead holding areas such as upstream of the DC bridge no longer exist 
4.   Dave Wellock’s agricultural
water system has been damaged w/o compensation while residential users have
been compensated, why the difference?
5.   Landowners have
lost river banks
6.   Summer water
Turbidity has been increased in violation of the Water Quality Control Plan for
the North Coast Region
7.   Noise
8.   Truck traffic
9.   And now a very
significant unmitigated impact brought forward at last week’s TAMWG meeting by
the Trinity County Weed Management Area- Noxious weed expansion.  Vague mitigation measures for this impact in
the Master EIR have not been implemented to prevent the spread of star thistle
and other species.
10.                 Navigational
impacts on the river from the side channels- drift boats must be dragged over
gravel bars at low flows, sometimes with salmon redds in them.
 
Information from the Science
Advisory Board’s Phase 1 review should also be made available to the public in
this environmental document for informed decision and an educated public.  However, only TAMWG members and agency staff
have received the draft report to date.  That is not right.  The public
should see it.
 
At this point, the benefits
of the projects are questionable at best.  The TRRP’s Science Advisory Board in the top secret draft Phase 1 report
made the following observations that I will report to you on:
 
1.   The initial
rehabilitation projects produced little to no immediate geomorphic
response.  
2.   ROD flows are
capable of eroding riparian berms and may not require mechanical intervention
as originally thought.
3.   In most cases the
increases in juvenile rearing habitat were not statistically significant in
term of absolute changes in habitat area
4.   System scale
monitoring shows that juvenile rearing habitat availability at base flow has
not changed significantly over the three year sampling period.
5.   Most of the
available Juvenile habitat is located in the Lewiston reach which for unknown
reasons exhibited a decline in mean habitat availability during the three year
sampling period
6.   Juvenile salmonid
rearing habitat availability has increased since 2001 but the rate of increase
is slow (1.2% -1.6% per year at base flows).  The goal is a minimum of a 400% increase in juvenile salmonid rearing
habitat.
7.   The program is
implementing the ROD, constructing habitat and monitoring physical and
biological response relative to objectives but integration of these efforts is
weak, particularly with regard to the program primary objective of fish
production.  
8.   We also note that
formal scientific hypothesis testing is frequently lacking in Program
actitivites.    …the program requires
stronger use of hypothesis testing for justifying study plans, making
defensible decisions and conveying results to peers and the public.
 
These projects are part of
the Trinity River Record of Decision (Trinity ROD), but there has been a lot of
deviation from the Trinity ROD and in some cases, the ROD has been wrong.  Could it also be wrong about the need and
projected effectiveness for creation of juvenile salmonid habitat for these
restoration projects?
 
1.   The ROD only
called for 3 side channels but many more have been built.  
2.   Engineered log
jams were not envisioned in the Trinity ROD, nor was boulder placement.  Neither of those were evaluated in the Master
EIR either.
3.   The amount of
gravel estimated to be needed was much larger than is now acknowledged.  There is a report by Dave Gaeman that admits
that.
4.   The bank feathers
are not producing the desired amount of juvenile salmonid rearing habitat, at
least without higher flows to reshape them but so far higher flows have not
substantially reshaped the projects.
5.   Flows are doing
more natural bank erosion than previously envisioned.  Bulldozing the river’s edge may not be
necessary.
6.   High Peak flows
for 5 days are not efficient at moving sediment. Most of the sediment moves in
the first day or 2.
 
The Trinity River Mainstem
Fishery Restoration EIS and subsequent Master EIR do not adequately describe or
evaluate impacts from the proposed projects.   There are significant unmitigated impacts and minimal benefits
demonstrated so far.  A full EIS/EIR is
required.
 
I’ve been a long time
supporter of this program but my confidence is really shaken now. I was always
willing to support the mainstem projects as long as it resulted in something
positive.  But now I can’t say that
benefits are worth the costs.  There have
been financial benefits to Weaverville from the payroll of the TRRP, but I’d
suspect that over half if not more of the total $15 million/year goes to out of
town payrolls, profit and overhead.  Local contractors feel left out.  Small watershed projects funded through local agencies provides
opportunities for local contractors that the mainstem projects do not but few
of them are being funded by TRRP.
 
Small watershed restoration
projects are a known and proven means of improving juvenile salmonid habitat
survival but are not being considered as an alternative to the mainstem
projects, which have yet to be shown significant benefits but certainly
significant impacts. 
 
Watershed restoration
projects also keep sediment from the tributary slopes out of the mainstem, which
reduces flooding of property, another project purpose and need.
 
Therefore, I’m asking you to
not approve these projects for 2014 and instead spend the money on watershed
restoration as envisioned in the Trinity ROD.  We asked you to do the same thing 2 and 3 years ago, but you didn’t
listen.  Now we have additional
information that clearly shows that a break in construction of these projects
is appropriate, as suggested in the Implementation plan for the Trinity ROD,
page C-8, Appendix C.  
 
“In interim period without construction activities may be necessary to
fully evaluate the effectiveness of project designs and the effect of the new
flow regime before beginning construction on the remaining sites.”
 
The benefits of these
projects are not pronounced but the impacts are significant and real opportunities
exist in the watersheds.  It’s time for a
change.
 
If you do wish to move ahead
with these projects, preparation of a full EIS and EIR is required. It is just
plain common sense and it’s required by law.
 
Thank you.
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