On Friday, February 23, The Sierra Fund (TSF) submitted lengthy written comments to the US Army Corps of Engineers Sacramento District (Army Corps) on their draft feasibility report for the Yuba River Ecosystem Restoration Study. In short, TSF asserted the following: 1) The feasibility report is scoped inappropriately. Rather than addressing watershed-wide restoration, the Army Corps focused narrowly on Lower Yuba River restoration. 2) More importantly, TSF believes that the Army Corps partnered with the wrong agency. Yuba County Water Agency (YCWA) has an inherent conflict of interest to protect their existing facilities, which may be threatened if the Army Corps pursues a watershed-wide restoration project.
Through careful review of the Army Corps feasibility report, TSF identified several significant flaws that we addressed extensively in written comments to the Army Corps. A categorical outline of our comments is as follows:
- Comment 1: The feasibility report relies on inaccurate and out-of-date information to draw inaccurate scientific and economic conclusions and develop ill-advised proposals for action.
- Comment 2: The feasibility report does not adequately explore the opportunities, benefits and costs of modification of the Army Corps facilities Englebright and Daguerre Dams (both of which block fish passage for endangered species), or the impacts of failure to do so.
- Comment 3: The scope of the feasibility report should have included the issue of fish passage as a central focus of this ecosystem restoration project.
- Comment 4: Yuba County Water Agency, with whom the Army Corps has signed a cost-sharing agreement for the program, has a conflict of interest related to their Narrows Dam project and other management priorities.
The Tentatively Selected Plan
The primary outcome of the feasibility report was the tentative selection of a plan to restore 178 acres of habitat on the Lower Yuba River between Englebright Dam and the Yuba-Feather confluence, one of a number of alternatives evaluated by the Army Corps in order to improve riparian habitat along the Yuba River. The Lower Yuba restoration project comes with a price tag of nearly $100 million. TSF believes there could be a more practical and economically viable project that would achieve watershed-wide ecosystem resiliency while simultaneously restoring volitional fish passage, improving water quality and promoting public safety.
We recommend that the Army Corps directly examines the accurate costs and benefits of modifying Daguerre and Englebright Dams to restore fish passage to the upper Yuba River watershed. TSF hopes that our comments and their scientifically-supported explanations will sway the Army Corps to reconsider the scope of their tentatively selected plan and their partnership with YCWA in order to fully evaluate project alternatives that would enhance ecosystem resiliency by restoring volitional fish passage to the upper watershed.