National Marine Fisheries Service Issues a Draft Jeopardy Opinion on Operation of Santa Felicia Dam on Piru Creek

On November 8, 2007, in a document that could have major effects on future operations at Piru Creek's Santa Felicia Dam by the United Water Conservation District, the National Marine Fisheries Service (NMFS) issued a draft biological opinion (BO) concluding that future operation of the dam in the proposed manner could jeopardize the existence of the southern California steelhead (more exactly, the Southern California Distinct Population Segment of the endangered steelhead that carries the scientific name Oncorhynchus mykiss). The BO also laid out a set of actions, termed a "reasonable and prudent alternative," that United could take to avoid the likelihood of steelhead extinction. It can be downloaded as a PDF file (15.2 MB PDF).

The NMFS document was issued as a result of the need for a new 50-year license for dam operation by the Federal Energy Regulatory Commission (FERC). The Federal Power Act authorizes the Commission to issue licenses for hydroelectric projects, including dams and reservoirs. Under the Endangered Species Act, the Commission must consult with NMFS if the licensing involves impacts to an endangered species that is within NMFS jurisdiction, as is the case for anadromous species that spend portions of their life cycles in the ocean.

Discharge from Piru Creek can provide a substantial amount of the total discharge of the Santa Clara River, and thus is of concern relative to steelhead migration. The proposed new 50-year license would allow United to reduce minimum flow releases from the dam into lower Piru Creek below the current requirement of 5 cubic feet per second. Additionally, the dam has no fish passage facilities and has blocked upstream migration of steelhead to spawning grounds in upper Piru Creek since its construction in 1953. The completion of Pyramid Dam in the early 1970s further fragmented the steelhead historic spawning and rearing habitat in Piru Creek. NMFS estimates that at least 38 miles of habitat for steelhead lies between Santa Felicia Dam and Pyramid Dam. The Piru Creek sub-basin forms one of the largest sub-basins in the Santa Clara River watershed (see map).

NMFS breaks down the effects of the proposed new FERC licensing agreement on steelhead into five major topics. The BO also points out that interrelated activities at the Freeman Diversion and Pyramid Dam are expected to exacerbate the consequences of operations under the new license.

First, dam operations would be expected to perpetuate the existing disruption of the migration of both adult and juvenile steelhead in Piru Creek and the Santa Clara River. The proposed operations regime includes no provision for releasing water in sufficient volumes to ensure a properly functioning migration corridor.

Second, dam operations would continue to disrupt spawning, incubation and emergence. Lower Piru Creek, a migration corridor, is generally not well-suited to steelhead spawning. Whatever spawning may take place, however, is impaired due to flow release schedules that do not support optimal spawning activities.

Third, the proposed operation would continue to harm juvenile steelhead. Decreased flows are expected to perpetuate reductions in the quality and quantity of living space for juvenile steelhead that migrate to the creek or migrate down from the remnant population above the dam. Additionally, young fish have been found to be adversely affected by the high flows released from the dam in early fall. These flows can start and stop quickly, resulting in potential stranding of adult or juvenile steelhead that may be in Piru Creek.

Fourth, steelhead would continue to be blocked from historical spawning and rearing habitat in the portions of Piru Creek above the dam.

Fifth, the likelihood of survival of the steelhead would be reduced. Population abundance is already at critically low levels and the effect of dam operations is expected to result in further reductions. The Santa Clara River steelhead population is considered to be one of only a few populations that have a high potential of being independent and thus constitutes a vital component in recovery of the species.

The BO also laid out a "reasonable and prudent alternative" to the proposed method of dam operations that would, in the opinion of NMFS, avoid jeopardizing the existence of steelhead. Three elements were identified in this alternative: (1) United should prepare a feasibility report for providing fish passage around or over Santa Felicia Dam and implement the preferred alternative; (2) United should prepare and implement a plan for improving the quality of steelhead habitat in Piru Creek downstream of he dam; (3) United should implement a plan to ensure that the timing and magnitude of water releases from Santa Felicia Dam be designed to provide unimpeded migration of steelhead both in Piru Creek and the Santa Clara River as well as provision of steelhead spawning and rearing sites in Piru Creek downstream of the dam.

Recovery of steelhead runs in the Santa Clara River has long been a top priority for the Friends. The southern steelhead was listed as endangered about 10 years ago. Since then, there has been a plethora of meetings, discussions, issuance of formal and informal documents, and studies. But effective action has not ensued, as evidenced by the fact that only a handful of adult steelhead have been observed in the Santa Clara River in recent years. Friends believe it is time, in fact way past time, to take the appropriate action. Still more studies are apparently needed. Those should begin immediately, followed by a set of actions that at least provide the steelhead a fighting chance to recover, not only in the Santa Clara River but in other southern California streams where it has been historically present. Please stay tuned.

Steelhead Recovery Plan Outline Released

The National Marine Fisheries Service (NMFS) released in September 2007 an outline on recovery planning for the Distinct Population Segment (DPS) of the Southern California Coast Steelhead (3.65 MB PDF). This DPS extends from the Santa Maria River south to the Tijuana River at the U.S./Mexican border and includes those portions of coastal watersheds which are at least seasonally accessible to steelhead entering from the ocean. Major steelhead watersheds north of the Los Angeles Basin include those of the Santa Maria, Santa Ynez, Ventura, and Santa Clara Rivers.

Factors that have combined to cause significant reductions in steelhead populations in the southern California costal area include human activities related to water development, flood control programs, agricultural activities and mining. As an example, one study estimated that California has lost over 90% of its estuarine habitat that is used by the steelhead for both rearing and acclimation to salt and fresh water.

The outline lists eight principal threats contributing to steelhead decline, including alteration of natural stream flow patterns, physical impediments to fish passage (mainly diversions and dams), alteration of floodplains and channels, increased sedimentation, waste discharges, loss of estuarine habitat, and stocking of hatchery-reared fish that compete with native juvenile steelhead for living space, cover, and food.

Specific priority recovery actions were identified in the Outline. On the Ventura River, these include removal of the Matilija Dam and completion of the Robles Diversion fish passage facilities. On the Santa Clara River, providing passage facilities and flows at the Vern Freeman Diversion commensurate with steelhead requirements and providing appropriate fish passage opportunities at both the Santa Felicia and Pyramid Dams on Piru Creek were listed.