of Califor latural Resources Agent =DMUND G. BROWN JR., Governor DEPARTMENT OF FISH AND WILDLIFE ‘CHARLTON H. BONHAM, Director South Coast Region 3883 Ruffin Road San Diego, CA 92123, (858) 467-4201 www.wildlife.ca.gov January 8, 2016 Ms. Kelly Rodgers ‘San Diego County Water Authority 4677 Overland Avenue San Diego, CA 92123 krodgers@sdowa.org Subject: Comments on the San Vicente Pumped Storage Federal Energy Regulatory Commission Project (FERC Project Number 14642-000) Pre-Application Document Submitted by the San Diego County Water Authority and the City of San Diego Dear Ms. Rodgers: The California Department of Fish and Wildlife (Department) has reviewed the above- referenced San Vicente Pumped Storage Federal Energy Regulatory Commission Project (FERC Project Number 14642-000) Pre-Application Document dated July 28, 2015 and materials presented at the Joint Agency Meeting held on November 9, 2015. This letter is provided in addition to the general comments provided in the Department's previous letter dated June 18, 2015, incorporated herein by reference. The following statements and comments have been prepared pursuant to the Department's authority as Trustee Agency with jurisdiction over natural resources affected by the project (California Environmental Quality Act, [CEQA] Guidelines § 15386) and pursuant to our authority as a Responsible Agency under CEQA Guidelines section 15381 over those aspects of the proposed project that come under the purview of the Califomia Endangered Species Act (CESA; Fish and Game Code § 2050 et seq.) and Fish and Game Code section 1600 et seq. The Department also administers the Natural Community Conservation Planning (NCCP) program. The San Diego County Water Authority (SOCWA) participates in the NCCP program by implementing their approved NCCP/ Habitat Conservation Plan and the City of San Diego (City) participates in the NCCP program by implementing their approved Multiple Species Conservation Program (MSCP) Subarea Plan (SAP). The Department is also the majority landowner of the property under consideration for the upper reservoir. ‘The proposed project would use energy to pump water from the existing San Vicente Reservoir (lower reservoir) up to a new Foster Canyon Reservoir (upper reservoir) for storage during Periods of low electrical demand, and generate electricity by releasing the water from the upper reservoir through the generating units and back to the lower reservoir during periods of high electrical demand, and as needed to support transmission grid operations. According to the project description, the exchange of water between the two reservoirs would be designed such that no water is consumed, and not interfere with existing water supply, water quality, fisheries, or recreational uses of the San Vicente Reservoir. The project would utilize a small portion of the total of San Vicente Reservoir's water capacity, such that at maximum pumping and generation, the San Vicente Reservoir would fluctuate approximately 2 feet up or down. New ‘small dams would be constructed to form the upper reservoir, and would be provided with a spillway section to provide safety against over-pumping, Any spillway overflow would be routed Conserving California’s Wildlife Since 1870Ms. Kelly Rodgers San Diego County Water Authority January 8, 2016 Page 2 of 4 back to the lower reservoir. A tunnel system and underground powerhouse would connect the two reservoirs. The powerhouse would contain four 125 MW reversible pump-turbines to provide maximum flexibility in both generation and pump-back mode. A new double-circuit 230 KV line would be built from the proposed project's powerhouse extending approximately five miles to the 230 KV Sycamore Canyon Substation (Sycamore) for regional transmission interconnection, ‘The Department offers the following comments and recommendations to assist the SDCWA and the City in avoiding or minimizing potential project impacts on biological resources and regional conservation planning in San Diego County. 1, The Department is concerned about the location of the proposed project in relation to the City’s San Vicente Cornerstone Bank lands, which are committed to conservation under the City's approved NCCP/HCP MSCP subarea plan. Additionally the project would impact County of San Diego-owned 100% conserved lands similarly dedicated to meet conservation requirements of the County's MSCP subarea plan. The regional importance of this large block of habitat was well established during the MSCP subregional planning. Removal of such lands from their 100% conserved status would require substantial consideration in regard to “making the NCCP/HCP preserve whole” when replacement lands are sought to offset the proposed project's impacts. This cannot be simply resolved through consideration of replacing the number of acres of habitat types that would be impacted, although habitat type and “value” (e.g. coastal sage scrub habitat value throughout the MSCP was ranked during the planning process), as well as sensitive species impacts must be part of the analysis. Subsequent CEQA/NEPA. documents must also consider the configuration of the preserved lands, edge effects, local and regional wildlife movement (including any effects beyond the project footprint), effects on the ability to monitor and manage the reserve, and other factors. It is uncertain at this time if a Major Amendment to the MSCP would be required; however, due to the potential effect on Comerstone Lands, which were pivotal to the City’s MSCP permit, this may be a necessary process. Changes to the bank area would also need to be documented by an amended to the Banking Agreement. 2. Numerous MSCP-covered or otherwise sensitive species are known to occur in the immediate area and may be impacted by the project. These include listed species such as quino checkerspot butterfly, least Bell's vireo, arroyo toad, coastal California gnatcatcher, and golden eagle. Other sensitive species known to occur include San Diego sagewort, San Diego County viguiera, Engelmann oak, red-eye tiger-ily, western spadefoot toad, orange-throated whiptail, San Diego horned lizard, San Diego banded gecko, coastal rosy boa, San Diego ring-necked snake, northern red-diamond rattlesnake, two-striped garter snake, California mastiff bat, pallid bat, and San Diego pocket mouse, many of which are covered species under the MSCP. Potential impacts to core populations of such species would require analysis of the assumed conservation under the MSCP to determine if the project (i.., the sum total of impacts and the assumed replacement conservation) would justify continued MSCP coverage for these species, 3. The Department requests development of an alternative that would avoid Department- ‘owned land. Loss of acreage from any Department-owned land occurs very rarely, in very limited extent, and typically only for purposes of public safety. Further, impacts to Department-owned or any other land which was purchased using federal Section 6 or Wildlife Conservation Board funding will require full replacement in value, from both aMs. Kelly Rodgers San Diego County Water Authority January 8, 2016 Page 3 of 4 biological and monetary perspective; even when dealing with very small acreages, this has proven to be a lengthy process. Additionally, to the extent a project is approved which may directly or indirectly affect the Department's ability to access or manage our remaining property, we expect that measures would be developed to fully address such subsequent concerns (e.g., unauthorized access, change to authorized access, erosion, introduction/spread of exotic species, etc.). The potential for impacts to other infrastructure, such as guzzlers, cisterns, and wells should also be analyzed, including how these resources could be replaced or augmented to maintain or enhance wildlife health and viability on the reserve. 4. The Department and the MSCP partners have made great strides in linking together Conserved lands that form a large block of intact habitat and act as regional wildlife Corridors linking to lands well beyond this core area. A construction project of this size would take an extended period of time to complete, resulting in the direct loss of wildlife habitat, disruption of wildlife movement, and/or disturbance to wildlife. Proposed new roads and existing roads would initially serve as construction routes, having both direct and indirect effects on flora and fauna (particularly reptiles and small mammals) over a large area as well as potentially impact areas that have been restored by the Department. The continued operation and maintenance may further have a negative long-term effect on the functionality of the wildlife corridor and core area. From a conceptual perspective, the Department is concerned that permitting a project of this magnitude within Department-owned land, or supporting significant impacts on 100% conserved lands designated for resource protection and compatible public uses, could adversely affect partnerships and planning efforts with multiple agencies, jurisdictions, and diverse stakeholders. 5. Due to our current responsibility as a land owner, the Department recommends analysis of potential impacts to cultural resources that could be adversely impacted by the project, including the Foster Truck Trail historic route. 6. According to the project description, the exchange of water between the two reservoirs would be designed such that no water is consumed, and not interfere with existing water supply, water quality, fisheries, or recreational uses of the San Vicente Reservoir. However, no mechanisms or mitigation processes were addressed in the Plan that would limit effects on fisheries or that would mitigate losses associated with this project. Of concern are the potential effects of water level fluctuation derived from water transfer activities (see below). Future surveys would be necessary to determine the total effect such activities would have on fish populations. Mitigation in the form of post-project, Monitoring (or funding to perform monitoring) to document effects, provide habitat improvement, and conduct fish stocking projects should be evaluated. The project should also comply with Fish and Game Code Section 5943, and allow public access to dam waters. a. Water level fluctuation is estimated to be between 1-2 feet. If water level fluctuations exceed 2 feet then impacts to juvenile fish would occur, eggs would desiccate, juvenile fishes would be more heavily predated upon, and optimal foraging and survival strategies for young fish would be negatively impacted. b. Water transfers that occur between the upper and lower reservoir also pose concems to fisheries. These potential effects include: direct impingement ‘mortality of juvenile fishes, changes in water quality and chemistry, altering lower reservoir dynamics through mixing processes, and altering oxygen levels at various depths,Ms. Kelly Rodgers San Diego County Water Authority January 8, 2016 Page 4 of 4 . San Vicente Reservoir is a known location for invasive quagga mussels. The plan does not mention quagga mussels, nor how the penstocks would be maintained clear of mussel growth. Waters that are heavily treated with chemicals in an effort to deter mussel growth would be detrimental to fish survival and would impact nearby recruitment. ‘We appreciate the opportunity to comment on the referenced project. We are hopeful that further coordination between the City, County, SDCWA, U.S. Fish and Wildlife Service, and the Department will be able to identify a project alternative that is feasible and ensures the continued compliance and implementation of ongoing regional conservation efforts. Questions regarding this letter and further coordination on these issues should be directed to Eric Hollenbeck at (858- 467-2720) or Eric. Hollenbeck@wildlfe.ca.gov. Oe opens Gail K. Sevrens Environmental Program Manager South Coast Region ec: Eric Porter, U.S. Fish and Wildlife Service ‘Oszar Biondi, San Diego County Water Authority Kelly Rogers, San Diego County Water Authority Scott Morgan, State Clearinghouse Timothy Konnert, FERC West Branch, Division of Hydropower Licensing Joshua Grover, CDFW, Sacramento Myra Herrmann, City of San Diego Jeff Pasek, City of San Diego