Draft EIS_072312.pdf - Middle Fork American River Project ...

20120723-4002 FERC PDF (Unofficial) 07/23/2012
expects these reintroduction efforts may possibly occur sometime during any new license
term of the project. The Public Draft Recovery Plan (NMFS, 2009a) identified the Upper
American River as a primary focus for recovery of Central Valley steelhead. Following
reintroduction, if it is eventually proven to be feasible, NMFS would then develop
recommendations for additional protection, mitigation, and enhancement measures to
protect listed anadromous fish.
However, there are a number of actions that would need to be completed prior to
reintroduction of Central Valley steelhead upstream of Folsom dam, according to the
biological opinion and draft recovery plan, including planning and scheduling,
permitting, evaluations, and funding. These include but are not limited to:
• evaluation of potential habitat in all three forks of the American River
upstream of Folsom and Nimbus dams;
• development of a fish passage pilot plan;
• implementation of a 5-year pilot reintroduction program that would include
construction of fish collection and tagging facilities, procuring equipment to
haul fish to identified release sites, and identification of downstream fish
passage options through reservoirs and dams; and
• development of annual pilot program effectiveness evaluation reports with a
final summary report due by the end of 2015.
Only after the final comprehensive fish passage report indicates that long-term fish
passage is feasible and desirable would full scale steelhead reintroduction upstream of
Folsom reservoir occur (NMFS, 2009b).
We note that there are considerable uncertainties regarding the viability and
implementation program set forth in NMFS (2009b). PCWA points out that at the time
its final license application was filed in February 2011 most of the actions associated with
the items listed above had not been implemented. NMFS (2009b) states that the concept
of collection of outmigrating juveniles at facilities at the head of reservoirs to ensure safe
and timely downstream passage of juvenile and post-spawn steelhead is untested, and
multiple concepts may need to be tested simultaneously. In the draft recovery plan,
NMFS (2009a) estimates that funding for the first 5 years of near-term feasibility studies,
habitat evaluations, development of reintroduction plans, and implementation of pilot
reintroductions for just the American River watershed would be about $50 million.
Obtaining funding to conduct these near-term actions, along with similar actions in other
targeted watersheds, will be challenging. Thus, the implementation of a long-term
steelhead reintroduction program is uncertain.
If and when steelhead are reintroduced into the upper American River watershed,
NMFS could exercise its reserved authority to prescribe fishways and could make
recommendations for additional terms and conditions to protect these species. NMFS
recommends that PCWA, in consultation with NMFS, Reclamation, FWS, and California
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