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Pajaro River background information
We are pleased to provide a report by Philip Williams & Associates
(PWA), “An Environmental Alternative for the Pajaro River Flood Plan”
(July 2003). This report proposes new alternatives for further analysis by the
U.S. Army Corps of Engineers (ACE) in its Feasibility Study to modify the existing
federal flood control project. We just submitted this report to the ACE, San Francisco
District. We now publish it in the hope that it will contribute to constructive
discussion by all Stakeholders about how best to provide needed flood protection
in the Pajaro River Basin in a manner that maintains and restores water quality,
the steelhead and other fisheries, and other natural resources protected by our
environmental laws.
PWA is an engineering firm that specializes in water resources planning and management.
It is routinely engaged by the ACE and local agencies to help design feasible
solutions where different purposes for river management, such as flood control
and environmental protection, appear to irreconcilably conflict. Click
here for a list of its representative projects. For example, it assisted the
ACE, Sacramento District in the redesign of the Napa River Flood Protection Project,
which will now protect the City of Napa against 100-year floods and also will
restore the tidal marshlands and floodplain. The ACE describes this project as
a national model for its mission of achieving flood protection in concert with
environmental protection and even restoration. The Sierra Club-Pajaro River Committee
engaged PWA to bring those same skills to bear on the Feasibility Study for the
Pajaro River Flood Control Project.
The ACE began the Feasibility Study following the 1995 and 1998 floods. It developed
a preliminary set of alternatives for modification to the existing project to
reestablish 100-year flood protection. As presented at the May 12, 2003 meeting
of the Stakeholders Group, the leading alternative (known as ACE Alternative 2A)
would raise and set back the levees, remove the riparian vegetation within the
active channel, and then routinely clear vegetation, sediment, and gravel on a
going-forward basis over the next decades.
Over the next 18 months, the ACE intends to take these alternatives forward for
further study of engineering and financial feasibility, as well as environmental
impacts. However, the regulatory agencies, which must permit any project modification
after the completion of such study, have already raised very substantial doubts
whether ACE Alternative 2A or similar alternatives would comply with applicable
environmental laws. These laws include: the Endangered Species Act, which prohibits
death or injury to the steelhead which spawn in this river; and the Clean Water
Act, which prohibits an increase in the suspended sediment load and otherwise
requires that a federal project protect all beneficial uses, including fish and
wildlife habitat. Following a February 10, 2003 letter by the Central Coast Regional
Water Quality Control Board that expressed such concerns, we met with the ACE
to request an expanded scope of alternatives in the Feasibility Study. Following
the May 12th meeting, the ACE fairly responded: what do you recommend?
We recommend that the ACE consider certain alternatives identified in PWA’s
report. PWA developed and then modeled six new alternatives to test whether each
would provide 100-year flood protection and also satisfy the performance standards
suggested by the regulatory agencies for compliance with environmental laws. On
the basis of preliminary analysis, PWA Alternatives 2, 3, 4 and 6 appear to be
very promising. See Report Sections 6.3, 6.4, 6.5, and 6.7. These alternatives,
which are variations on a new strategy, would lower the active channel to approximately
its historic level, provide for the safe passage of the 100-year flood, and permit
the reestablishment and maintenance of riparian vegetation and other fish and
wildlife habitat. While each would require significant sediment removal in the
initial reconstruction, that would reduce the long-term maintenance burden by
an even greater amount, since the channel would regain its geomorphic stability.
We believe that upstream storage, which is a potential feature of any downstream
alternative, is also a very promising strategy, since it would reduce the peak
flow that must pass between the levees. See Report Section 7. We note that Professor
Robert Curry (California State University, Monterey Bay) has recently published
an independent
report about the feasibility of this strategy.
The 1944 and 1966 authorizing statutes expressly require that the project provide
flood control and achieve multiple purposes, including protection of the fish
and wildlife habitat and other public uses of this river. These statutes also
provide for consideration of an upstream storage strategy. Under the ACE’s
general rules, the ongoing Feasibility Study must consider the benefits and costs
(including the costs of operation and maintenance) of each alternative over the
project life, and it must identify the buildable plan which best achieves all
of the authorized purposes.
We thus request that ACE, in coordination with the Counties as local sponsors,
regulatory agencies, and other Stakeholders, give careful consideration to PWA
alternatives 2, 3, 4, and 6 and upstream storage, along with those alternatives
already on the table. We will assure that PWA experts are available to participate
in further technical analysis and refinement of alternatives. More generally,
we are committed to help develop and implement the best alternative that will
provide 100-year flood protection in a cost-effective manner that also protects
and restores environmental quality of the Pajaro River, as required by the authorizing
statutes.
Please contact Lois Robin at 831-464-1184 or JoAnn Baumgartner, Co-Chair at 831-761-8408
if you have any questions about this report.
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