Our View: MID must contest flawed FERC impact statement

When the Federal Energy Regulatory Commission grants a license to operate a dam, it usually lasts 50 years. So you want to get it right.

Unfortunately, much of what we’ve seen in the 645-page Draft Environmental Impact Statement that would govern Merced Irrigation District’s operation of New Exchequer Dam doesn’t strike us as right or acceptable.

▪ Where are the steelhead? Various state and federal wildlife agencies want MID to release 47,000 acre-feet of water from June to mid-October to help steelhead have a more comfortable summer in the river or go back out to sea. But Merced steelhead are a myth. Yes, conditions are right for steelhead, and it’s likely steelhead once swam in the Merced. But there hasn’t been a steelhead spotted or caught in the river in 20 years of intensive study.

Even FERC calls the presence of steelhead “likely,” not certain. Taking so much water from those putting it to good use on the “likely” chance that there are fish that need it isn’t rational. A steelhead is a rainbow trout that swims out to sea, feeds heartily and returns to the river of its origin. Rainbow, steelhead – same fish. But you can’t force a rainbow to leave the river of its birth if it would prefer to remain a rainbow.

This year, water is selling for at least $700 an acre-foot, putting the value at $32.9 million. So the government wants the people of the district to forfeit $32.9 million to protect a fish no one has seen in 20 years. Before the federal government spends that much of our money, we’d like to know that it will actually do what’s intended. Non-native bass kill virtually all of the juvenile salmon that reach the San Joaquin River; they would do the same to steelhead.

Shouldn’t FERC first request the environmental agencies to guarantee safe passage for these fish before we provide the water?

▪ How much water? Over the past 40 years, the Merced has provided 1 million acre-feet of water on “average.” Recognizing average doesn’t exist (it’s either wetter or drier), about half of that water remains in storage behind New Exchequer Dam each year, where it was first used to generate electricity before being used to irrigate crops.

For the past 20 years, the district has provided roughly 180,000 acre-feet per year for environmental purposes – keeping the Merced flowing year-round, watering the Merced River National Wildlife Refuge, and helping salmon come and go in the fall and spring.

The federal government wants a 58 percent increase in environmental water, from 180,000 acre-feet to 286,000 acre-feet.

“The real impacts,” said Bryan Kelly, MID’s deputy general manager for water resources, “will be felt in the critically dry years. That’s when you need the water the most. … Our growers are going to feel that significantly.”

Ask farmers how much they’re getting this year – nothing. There’s nothing left to give.

▪ Counting water. FERC wants water planning done using the Hughes Method rather than the industry’s more familiar formula. The Hughes Method was developed by a wildlife expert to estimate water flows, and is accurate for high mountain reservoirs. It is less accurate on storage reservoirs. Why is this important? Because water releases are based on the classification of wet, dry or critically dry years. The Hughes Method tends to predict more wet years that turn out to be dry than the other way around, meaning the state could require more water to be released for fish in those years.

“It’s a significant difference,” said Kelly, noting outflow numbers would be set in February when wild fluctuations can still occur. “So you end up releasing a whole bunch of water, and then there’s no getting that water back.”

▪ Shocking cost. Obviously, powerhouses at the dam generate power. By requiring more environmental flows, the district will lose roughly $650,000 per year in electricity generation.

No one expected relicensing to come without costs, but several components of the FERC environmental draft should be addressed before being accepted. Providing enough water for a viable salmon population is necessary, as are many of the habitat recommendations. But depriving the region and its farmers of vast amounts of water on the offhand chance that one or two rainbow trout might decide they’d rather be steelhead is wasteful folly. It must be vigorously contested.

FERC’s enormous document is still a draft, and it is accepting comment through May 29. Other water districts should join MID in contesting this flawed analysis.

This story was originally published May 8, 2015 at 5:31 PM with the headline "Our View: MID must contest flawed FERC impact statement."