Protect Flows on the South Fork American - Submit Comment on NOP Permit 21112 Project
The El Dorado Irrigation District wants to modify its Water Rights to allow for additional water extraction. Public comments on the NOTICE OF PREPARATION are due as early as possible, but not later than 5pm October 20. Please share this opportunity with your networks. To comment, you must include your name and mailing address in the body of an email, and NOP Permit 21112 Project in the subject line. The example below reflects FOR's recommendations. Please email your comments to: P21112NOP@eid.org
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From: First Last, Street Address, City, State, Zip
I am writing to oppose the proposed modifications to EID’s Water Right Permit 21112 and to request a thorough analysis of its impacts to the South Fork American River and ecosystems, including the economic well-being of El Dorado county residents. Changing the diversion point for 17,000 AF of water to an upstream location at the existing El Dorado Diversion Dam near Kyburz on this river will have severe consequences to downstream recreational and environmental resources across the watershed. Between Kyburz and Folsom Reservoir, there are over 50 miles of whitewater recreation opportunities for local, national, and international visitors and paddlers who annually spend their money on El Dorado County businesses. Additionally, how the change of diversion impacts the environment and the county is not clearly described in the proposal.
I would like to remind the current EID Board and staff that, two decades ago, El Dorado County Water Agency on behalf of EID formally committed to only diverting water from Folsom Reservoir under this water right. This was done to address the overwhelming recreational and environmental concerns voiced by many groups and individuals who blocked State of California approval due to the effects on the South Fork American River. That being said, the Draft EIR for the new proposal must address some specific concerns.
The river and surrounding public lands provide outdoor recreation vital to public health and well-being. Thus, the Draft EIR for this proposal must identify all impacts of the new diversions on whitewater boating flow levels downstream of Kyburz, Slab Creek Dam and Chili Bar Dam. A change in flow levels would reduce the beneficial public use of paddling resources like the Kyburz and Golden Gate paddling runs that depend on instream levels appropriate to recreate. Upstream diversions could also severely impact scheduled recreational flows required by the hydropower licenses for both the Upper American River Project and the Chili Bar Project.
In addition to the impacts to recreation, how the change of diversion impacts the watershed environment must be clearly described. The Draft EIR must clearly address impacts of climate change and assess the ramifications of growth in the service area. Combined climate change and growth intensify the consequences for on water use. The DRAFT EIR must address wildfire impact, forest health, water temperature/flow/quality, risk of harmful algae, riparian habitat and cascading impacts to threatened or endangered species.
Finally, the Draft EIR must address impacts to the local community and public interest. The South Fork of the American river has been designated as “suitable” for Wild and Scenic status by the BLM, due to cultural as well as recreational value. The river is integral to the public experience at Marshall Gold Discovery State park, which is a historic centerpiece of California history, visited by tens of thousands each year. Tourism in El Dorado County is critical to a healthy economy. The Draft EIR must address the potential cultural losses to people of California, and economic losses to El Dorado county businesses.
The Draft EIR must make a serious effort to define the criteria by which EID would decide when, how, and in what quantities to use the added upstream diversions under Permit 21112. EID must also describe how District water supply operations on the whole would change and quantify water sales outside of El Dorado County. The public cannot make informed decisions about the consequential impacts without more information, data, and modeling.
Overall, it is my hope that the current EID Board and staff will honor the commitment to protect vital recreation and our environment on the South Fork American River by dropping the proposal to relocate their diversion.