The U.S. Fish and Wildlife Service has recommended ending summer whitewater releases on the Pit River (Fall River Mills to Pit 1 Powerhouse) in the interest of protecting the endangered Shasta Crayfish. Here at American Whitewater, we believe that this recommendation has been made with little evidence showing a correlation between the releases and the dwindling crayfish population. More importantly, the U.S. Fish and Wildlife Service staff working on this project has stated that they gave no consideration to the impact their recommendation would have to whitewater recreation. We think this is wrong!

WHAT YOU CAN DO RIGHT NOW
Write to FERC and the State Water Resources Control Board to let them know that these releases are an important recreational resource. Don't let them end prematurely without further study. These runs are immensely popular as detailed in the March-April issue of AW Journal. This is a run for everyone, novices and aficionados alike. If you want these releases to stay please write a letter to FERC and the State Water Resources Control Board. American Whitewater's letter is included below for reference.

Please send letters ASAP and preferably before June 12th. The first Pit release is scheduled for June 20-21st.

You have three options for filing comments with FERC:
1) you can register directly on the FERC website <http://www.ferc.gov> and electronically file, This option allows you to subscribe to the docket and follow the process. Select the eFile option on the website (please contact me if you would like additional assistance).
2) you can file by mail using the address below.
3) you can email your comments to AW and our Conservation Assistant Carla Miner can file on your behalf.
carla@amwhitewater.org and a cc to me dave@amwhitewater.org.

Please also send your letter to the State WateR Resources Control Board


KEY TALKING POINTS (use the attached template,on the right under documents, with project name, Pit 1, and number, P-2687)
• How far you travel to be able to take advantage of this run.
• Describe the importance of having whitewater boating opportunities in the summer.
• Describe the unique qualities of either/both the class IV reach above the powerhouse or the class II reach downstream.

That's It. If you can make those points you will have played an important role by documenting public interest in this river.

Send letters to:

Ms. Kimberly D. Bose
Secretary
Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426

Ms. Victoria A. Whitney, Deputy Director
Division of Water Rights
California State Water Resources Control
1001 I Street, 14th Floor
Sacramento, CA 95814

American Whitewater is opposed the request by the U.S. Fish and Wildlife Service (USFWS) to eliminate the flushing flows the are required a s described in article 401 of the FERC License for the on the Pit1 Project (FERC) Project No. 2687. As an intervener on this project we are particularly disturbed that this recommendation was filed with FERC and the State Water Resources Control Board without any consultation with American Whitewater. The failure to have an opportunity to comment on this process until now is particularly troubling, and not in the spirit of collaboration that we have worked hard to establish with our agency and utility partners.

Elimination of these flushing flows that occur one weekend per month, June through August would also eliminate a very important whitewater recreation opportunity for the paddling community and their families. The letter from USFWS seems to indicate that the only purpose for the releases is to flush vegetation. This is incongruous with the fact that whitewater boating use counts have been documented by PG&E every year that these flows have taken place. PG&E also conducted a whitewater boating flow study in 2006(Pacific Gas and Electric Whitewater Flow Impact Study Final Phase 2 Report, Accession Number: 20080327-5017).
Availability: Public, specifically to better determine the flows necessary to meet the needs of whitewater recreation. American Whitewater did not oppose the new license when it was issued in 2003 because, in our view, the flushing flows included in the license would meet the need to provide whitewater recreation on this project. Over the past several years over a thousand kayakers, rafters, and whitewaters canoeist have come to take advantage of the releases on the Pit. This opportunity is unique in that it provides both a class IV run in the bypass reach and a class II run below the Pit 1 Powerhouse. This combined with great camping at the BLM campground, located just downstream of the Pit 1 Powerhouse, creates and ideal situation for families who wish to have a paddling weekend with options suitable for younger children.


While American Whitewater is sensitive on the need to be protective of the Shasta Crayfish, the linkage to the reduction in the Shasta Crayfish population and the flushing flows is not well articulated in the UFWS letter or in the report provided by PG&E, (Shasta Crayfish Technical Review Committee Summary Report, May 200, Accession Number: 20090528-5081,). American Whitewater has a number of concerns regarding the lack of clear rationale supporting the recommendation to eliminate the flushing flows. For example, both the letter and the report cite the increases in water temperature having harmful effects, however, it is unclear if water temperature readings were actually taken in the limited areas where Shasta Crayfish are known to reside. In addition, the letter also cites that water temperatures increased to 21 ˚C during the releases, however again, neither the letter nor the report state what the beginning temperature was before the release. Further, neither the letter, nor the report, cite any specific studies showing that short-term temperature variations up to 21˚C can be lethal to Shasta Crayfish. Finally, the USFWS letter also fails to cite the fact most of the other Shasta Crayfish populations in the surrounding area have also seen similar declines absent flushing flows.

Based upon our review of PG&E's Shasta Crayfish report, we found several important relevant pieces of information that bring into question the linkage between flushing flows and declines of crayfish populations. We think it is significant that in the early surveys (1978), Shasta Cray fish were found below the Pit 1 powerhouse. At that point in time this section of river peaked 2000 cfs per day and had been doing so since 1922. What is clear from PG&E's report is that the increase in the numbers of Signal Crayfish, an invasive species, has had a negative effect on Shasta Crayfish populations. The report also documents substantial efforts in other areas near the project, to modify existing Shasta Crayfish habitat in order to protect them from Signal Cray Fish and other predators. We suggest that these mitigation efforts should be undertaken on the Pit 1 bypass reach as well. We would like to explore the possibility of these kinds improvements to see if they could be constructed in such a way to keep out predators and elevate concerns of water temperature increases during flushing flows on the Pit River.

Our request is that more information be collected before any changes are made to the license regarding flushing flows. Specific information requests include:

• What are the actual changes in temperature at the locations that Shasta Crayfish are known to exist in the Pit 1 bypass reach?
• What are the temperature change tolerances for Shasta Crayfish? (Here we recommend looking at the daily temperature changes that existed below the Pit 1 Powerhouse when Shasta Crayfish was known to exist there).
• Are the populations of Shasta Crayfish showing reductions in population, that are different as compared to other populations decreases in the area?
• Can we build a protective structure that would keep invasive species out and cold water in?

American Whitewater wishes to be apart of any decisions made concerning this extremely important river resource. It is our hope that we can reach a management solution that meets the needs of all of the stakeholders who have an interest in this project.

Sincerely,


Dave Steindorf
California Stewardship Director
American Whitewater