RVWA-SIKO Comments for Little Baja Fish Release Initial Study-Final1

Rio Vista Windsurfing Association Sherman Island Kite Boarding Organization

P.O. Box 547 Rio Vista, Ca 94571 June 8, 2014 Kathleen Buchnoff, P.E. Senior Engineer California Department of Water Resources Bay-Delta Office, Delta Conveyance Branch 1416 Ninth Street, Rm: 252-17 Sacramento, CA 95814 (916) 653-6426 [email protected] Subject: Little Baja and Manzo Ranch Fish Release Project Mitigation On behalf of the over 1,500 past & present members of Rio Vista Windsurfing Association and Sherman Island Kite Boarding Organization (RVWA-SIKO), we appreciate the opportunity to work with the Department of Water Resources (DWR) to successfully complete the “Little Baja” fish release project and associated mitigation measures. The State Water Project has many unanticipated impacts including the devastating effects on endangered species such as the fragile Delta Smelt. The need to prevent the predation of salvaged fish from the State Water Project Pumps is apparent and we commend the DWR in taking a lead in preserving the waters of the Sacramento River for generations to come. It is also important to recognize and protect the unique resource the area offers the thousands of water enthusiasts that use the area regularly and minimize their impacts. During our only discussions on May 29, 2014, RVWA-SIKO learned that the planned construction activities will impact access to the Sacramento River for 2 complete seasons starting next year and that 4 of our 5 launch sites could be affected during construction. It is unfortunate, that there was no public outreach or contact with our group, the County Park Rangers and users, or the surrounding neighbors prior to this meeting. As a longtime partner in the use and management of the corridor, we feel it is critical that there be a public outreach and coordination with the users that will be affected by the project. Our main objective is to maintain current kiting and wind surfing sites and improve access to the river for all users of the Bay Delta waters. We realize that temporary adjustments will be needed during the construction process and we welcome the opportunity to help implement both long and short term mitigation measures that satisfy all parties’ needs and requirements.

RVWA-SIKO Letter DWR –Little Baja Fish Release IS of 14 June 8, 2014

RVWA-SIKO has a long history of successfully working with the DWR on various projects along the Sacramento River. Since the early 1980’s our members have promoted safe access to the river with minimal impacts on the natural environment. Our members along with the members of the local community take great pride in preserving the beauty that Sherman Island has to offer. Our commitment

to the environment is evident by our by annual Delta Cleanups. This past spring RVWA-SIKO members along with the Delta Conservancy and local Rio Vista High School students removed over 3000 lbs of trash and 285 tires from the shores of the Sacramento River along West Sherman Island Levee road. As Californian’s, we are blessed with the bountiful resources that the Sacramento / San Joaquin Delta region has to offer. The windsurfing and kiting in the area around “Little Baja” is world famous supporting visitors from all over the globe. Indeed, the name “Little Baja” comes from the fact that many of our members “migrate” south to Baja California, Mexico in search of similar wind and water conditions during the winter months. Several projects that RVWA-SIKO has worked together with the DWR, the Sacramento County Parks and Recreation and the California State Parks include providing safe access to the river at various sites including:

The Powerlines - a windsurfing launch located under the first set of Powerlines crossing the Sacramento River on West Sherman Island Levee road. Unfortunately, this site was negatively affected by the recent windmills which appear to have disturbed the laminar wind flows on the river and rendered the site less viable for wind sports. Due to the Windmills, the winds and wind enthusiasts have shifted more towards the County Park which has impacted the park facilities and put an even greater demand on the “The Sign, Little Baja, and the Access.”

The Sign – a key windsurfing launch located just west of Rio Viento Campground. It is our understanding that the fish release project will have no impact to this site during construction. Except that the powerpole located at the far west end will need to be accessible for a few days to connect power. Please confirm that this area will remain open from April 1 through October 1 each year.

Little Baja – -is both a kitesurfing and windsurfing launch located where the levee road dips down to the tow of the levee. This site is one of the original windsurfing sites but has changed over the years to be one of the premier kitesurfing launches. It is the only safe egress from the river for distressed windsurfers and kiters who have launched down river at the county park and is the only kitesurfing launch outside the park. Please confirm our understanding that the intent of the DWR is to provide similar access to this site after construction even though the proposed road runs through the current parking area. What is the final parking configuration?

Figure 1 - RVWA-SIKO Levee Clean-up


Senorita Beach – a windsurfing launch (there is no beach) located along the dirt access road southwest of Little Baja. The site had 2 sets of wooden steps on the dry side of the levee and river access points which were built by volunteers of RVWA and a local Boy Scout Troop in Rio Vista. Unfortunately, this site was destroyed when the Army Corps of Engineers made levee repairs several years ago.

The Access – a multi use site at the end of the dirt road (at the toe of the levee) located just before the county park. One of the more heavily used sites throughout the summer especially when the county park has reached capacity. The 4 sets of ramps and stairs built by RVWA-SIKO volunteers were removed and the site shut down when the Army Corps of Engineers performed levee maintenance. The stairs were never restored. RVWA-SIKO has been working with the DWR and the local rancher to share the site temporarily until the fish release project is completed. However, we understand that a proposed staging area may eliminate this site all together during construction. Mitigation measures need to be implemented to keep this site open during construction. Alternatives to the contractor’s staging areas can be found. What other alternatives has the DWR considered?

The County Park – a multi-use site maintained by the County of Sacramento and initially improved for kiting and windsurfing by RVWA. This site is famous among kiters and windsurfers and is key launching area for boating, kiting, windsurfing, standup paddle boarding and swimming. During the summer months this site is often at capacity with overflow of recreational users spilling in the “Access” and little “Baja” areas. The current Park Rangers, who are doing a fantastic job, have their hands full and it is our understanding they were not consulted about the pending influx of potential kiters, windsurfers and other recreational users who will be displaced by the fish release project.

Windy Cove – located at Brannan Island State Park. This windsurfing and kiting launch was built together by the CA Department of Parks and Recreation and RVWA-SIKO volunteers who spent considerable resources and lobbying efforts. Unfortunately, this site was permanently shut down in 2010 due to erosion concerns and budget cuts which increase the use of other launches like “Little Baja” and the County Park. Why can’t this site be used as an alternative fish release site? Or the abandoned dock just to the southwest of the Brannan Island Bridge?

With this history in mind, it is extremely disappointing that the Initial Study (IS) for the fish release project did not once mention that RVWA-SIKO is an impacted entity. What section(s) of the revised IS will the historic use of the area be documented; including the safety aspects of “Little Baja”? Keep in mind that of the entire 447 mile run of the

Figure 2 - Windy Cove - CLOSED


Sacramento River only the last 2 miles is navigable and conducive for both kiting and windsurfing. The Little Baja Project could affect over 75% of the kiting and windsurfing access to the navigable waters of the Sacramento River for over 2 years. In order to contend that the IS findings are “less than significant”, RVWA-SIKO requests a separate Mitigation Section of the IS to address the loss of access to the navigable waters of the Sacramento River. This section should include the following mitigation measures which appear necessary to completely close the “Little Baja” launch site during construction.

1) Move the proposed Staging & Spoil Area Site “A” into the current location of “Little Baja” parking area and expand as necessary along the south side of the levee road and into the large area to the east up to, but not including, the area of “The Sign”. This will allow for continued safe access to the Sacramento River and allow for safer kite launching during the 2 season construction window.

2) Move the temporary road completely out of the way and “T” it into Sherman lake road which will maintain the windsurfing and kiting launch site to the river at “The Access” between April 1st and October 1st during each calendar year. Construction operations and river access at the “Access” could be separated by a standard construction fence running adjacent to the new road.

3) Restore the stairs and river access previously removed at the Access and Senorita Beach after construction.

4) Restore the parking area at “Little Baja” after construction. 5) Restore the access to the river at “Little Baja” after construction. 6) Restore pedestrian/bike access on Crown Road after construction. 7) Restore the damaged grasslands, fences, signs, and grazing pastures after

construction. With these mitigation measures in effect, we are confident that the impacts associated with the State Water Project projects requirement to build multiple fish release sites will be minimized. We invite the opportunity to discuss these proposed mitigation measures with you further and request that each comment be addressed in the final IS document. The diagram below shows the construction staging required which could reduce projects cost and maintain safe access to the river during construction.


Figure 3 - Proposed Construction Staging Plan Minimizes Impacts & Reduces Costs

The first order of work would be to build the new road as far south as possible against the existing fence. Move traffic off the upper crown road from Station 691+00 to 745+00 for construction and to provide safe river access for recreational users from stations 691+00 to 697+00. Complete the “Access” launch and reduced parking area. Building the new road first avoids having to build temporary roads through the active construction project. The final configuration after construction would provide safe access to the river by not having pedestrians cross an active roadway, increase the survivability of the fish, and decrease cars parking on the levee road.


Figure 4 - Final Configuration provides safe access to the River with no road crossings.

The above mitigation and final configuration will alleviate many of the shortcomings found in the Initial Study. After a detailed review of the IS, the following suggested changes are needed to maintain that that there is “Less Than Significant Impact “ by the installation of two fish release structures and associated levee maintenance. Detailed comments on the Initial Study: On page ii under Findings: the following revisions should be addressed:

1. The proposed project would not impact cultural resources, land use and planning, mineral resources, population and housing, public services, recreation, or utilities and service systems.

2. The proposed project would have a less than significant impact to aesthetics, agriculture and forest resources, geology and soils, greenhouse gas emissions, hydrology and water quality, noise, and transportation and traffic.

3. Mitigation has been adopted by DWR to reduce potentially significant impacts related to air quality, biological resources, recreation, loss of access to navigable waters, and hazards and hazardous materials.”


On page vii add the following sections prior to the “Statement of No Significant Effect:”

Recreation As an environmental and recreational commitment, an outreach meeting between the local Windsurfing and Kiting groups, Rio Vista Windsurfing Association and Sherman Island Kite Boarding Organization (RVWA‐SIKO) will be conducted with the Sacramento County Park Rangers to facilitate construction information and site limitations during construction. Although the Sacramento Regional Park is just outside the project limits, construction will displace many of the recreational users who use the area within the project limits. Completely closing the area could significantly impact the County resources and have a negative effect on the overall construction process. In addition, the following mitigation measures will be implemented. Mitigation Measure Rec-1: Minimize impacts to Sacramento County Regional Park during construction, and compensate for unavoidable impacts. The Construction in some areas within the project limits will be restricted to occur during the off season of recreational enthusiast. No work in these areas will occur between April 1 and October 1 to minimize potential recreational impacts both within and outside of the Sacramento Regional Park. Due to the closing of river access points known as “Little Baja” and “Senorita beach”, river access points known as “The Access” and the “The Sign” will remain open between April 1 and October 1. Upon completion of the project, the river access points will be returned to multi use area and off levee parking. After construction the site will continue to be maintained by the existing joint efforts of the DWR, RD341 and RVWA‐SIKO. Mitigation Measure Rec-2: Minimize impacts to jurisdictional waters of the United States and waters of the state during construction, and compensate for unavoidable impacts. The closing of “Little Baja” Kite launch will have potential significant impacts on the Sacramento County Regional Park. To avoid completely removing the river access and the only safe egress within the project limits, river ingress/ egress will be enhanced at “The Access” to facilitate kite launching and exiting in accordance with the recommendations of RVWA‐SIKO and the County Park Rangers.

On page 1-1 under “1.2 Project Purpose” add the following in bold:

Improvements will widen the levee crown at the location of the fish release sites to allow operation of the fish release facilities, enhance the existing access to the river for recreational activities, provide safe pedestrian access, and improve the safety of traffic on the county road. The coordinated efforts between DWR and RD 341 will ensure that the needs for the fish release sites are incorporated into the levee and road improvement design and that the fish release site design includes the final levee design and incorporates the DWR and public trust commitments to provide access to the


Sacramento River for recreational activities including fishing, kitesurfing, windsurfing and standup paddle boarding.

On page 1-3 under “1.3 Project Location and Setting” add the following in bold:

…The sites are located southwest of the Rio Viento RV Park and northeast of Sherman Island County Park. The area is currently being used by RVWA‐SIKO and others as a kitesurfing and windsurfing launch into the Sacramento River. Kiters and windsurfers from the Sacramento County Regional Park also use the site as a safe/emergency exit point from the river. RVWA‐SIKO has maintained the site since the 1980’s and provides sanitary facilities for all recreational users. The DWR in partnership with RVWA‐SIKO will provide appropriate alternative access to the river during construction… …The area where the toe berm will be placed is mainly comprised of the existing levee slope (including the county road), recreational parking and irrigated pasture. Two staging and spoil areas have been identified to address construction requirements and seasonal recreational usage. The primary staging and temporary spoil area is located between stations 735+00 and 750+00 it is approximately 1400 feet long and averages 250 wide (7.8 acres). Temporary access to the staging area will be constructed starting as station 749+00. approximately 500 feet downstream of the Little Baja fish release site and is situated adjacent to the levee. It is approximately 700 feet long and 150 feet wide (2.4 acres). The secondary staging and temporary spoil site is located next to Manzo Ranch release site and is adjacent to the levee. It is approximately 700 feet long and 50 feet wide (0.8 acres). The staging and spoils areas are mainly comprised of opens areas with weedy, non‐native annual vegetation. See Figure 2 (REVISED) for staging and spoil area locations.…

On page 2-1 under “2.1 Project Features” add the following in bold:

• Installation of two low profile automated site access gates for access to the sites from the county road to the release site access road on top of the levee. The gates will allow for the existing pedestrian access to be maintained after construction.

• Providing electrical service, via a new PG&E pole line that will be constructed on the south side of the new roadway, and running underground conduits from the PG&E poles to the fish release facilities to minimize impacts to recreational users and mitigate aesthetics impacts.

On page 2-1 under “2.2.1 Levee Improvements and County Road Realignment” add the following in bold:

…The proposed levee improvements will increase the width, height, and integrity of the levee section and realign the county levee road at the new salvaged fish release sites. The improvements will accommodate the existing recreational users which use the


site to access the navigable waters of the sacrament river. The DWR and RD341 in cooperation with RVWA‐SIKO and the County Park have mutual understanding that all improvements will meet the criteria set by the CVFPB and USACE …. …The county road improvements will consist of demolition of the existing toe road and construction of a new toe road with new tie‐ins on top of the levee crest at station 739+00 and along the existing Sherman Lake Marina Road 250 feet south east of station 691+00 . To minimize traffic and pedestrian safety, the alignment will accommodate parking for seasonal recreational users on the levee side (north side) of new road.

On page2-2 under “2.2.2 Site Access Gates” add the following in bold: …The automated gates are being installed to limit vehicle access to the gravel road along this stretch of the levee and for security of the release sites and operators. The gravel road will be improved during the RD’s levee improvements. For ease of the authorized vehicles using the fish release facilities, the gates will be low profile automated vertical swing gates operated using a remote control. Each of the automated gates will require a footprint of approximately 25 feet by 10 feet for installation of a gate post, bollards for pedestrian access, operating system, and protective guard posts. The posts and operating systems will be supported using localized, below‐grade reinforced concrete pad foundations. (Figure 3 to be revised)

On page 2-6 under “2.2.6 Power at the New Sites” consideration should be given to placing the power lines underground and mitigate the visual impacts associated with the new 14 planned power poles and access road and other fish release structure requirements. If deem absolutely necessary, the new poles need to be placed on the south side of the new toe road which should be constructed on the southern boundary of the project limits to maximize safety concerns associated with the historic recreational site usage. On page 2-7 under “2.2.7 Staging and Spoil Areas” this section needs to be revised in accordance with the new section “1.3 Project Location” and identified in the revised figure 2. On page 3-1 under “3 Environmental Checklist” the section Recreation needs to have an “x” due to the added burden of the County Park and impacts to current site users. On page 3-2 under “3.1 Aesthetics” at a minimum sections a, b, c, d all need to be in the “Less than Significant with Mitigation Incorporated” column. The IS statements that “There are several structures along this particular stretch of the Sherman Island Levee (West Sherman Island Road) that would be similar in size and aesthetics to the proposed fish release sites” appears incorrect. There are no structures within the project limits and


the only similar structure, which should be incorporated into the fish release program instead of building the Manzo Ranch site, is located almost 3 miles away and is not visible. This section fails to mention that pedestrians have enjoyed unobstructive views of Mt Diablo, a major California land mark, and waters of the Sacramento River Delta.

On page 3-2 under “3.1.2 Discussion” section . The current language assumes that the only scenic vista is from State Highway 160 which is located several miles away. Due to the distance from highway 160 at this location, the Sacramento River cannot even be seen. However, the scenic vistas enjoyed by recreational users of the County Park, boaters, sailors, and pesistrians who come to this scenic section of river would be significantly impacted without mitigation measures implemented. This section should be revised to include the following:

Less-than-significant with mitigation incorporated. The levee road around Sherman Island is considered a scenic corridor in the Sacramento County General Plan because of views of the Sacramento River. The project site is adjacent to a Sacramento County Regional Park. Mitigation Measure A-1: Reduce Aesthetic impacts associated with the fish release structure improvements. The DWR should implement the following measures to mitigate the aesthetic impacts.

• Low profile gates on crown road which allow pedestrian access. • Low wattage LED Lighting that is motion sensitive and also activated by a switch

will be utilized at the fish structures.

Figure 5 - Visual Impact Simulation


• Security fencing and gates at the fish structures should be minimized and native vegetation up to 6 feet in height should be planted on both sides of the structures to screen views.

• The fish release pipe should be reinforced so that log booms protruding in the water are not needed.

• Powerpoles all utilities routed underground from the last existing powerpole. • The revised location of the levee road and parking areas at the toe of the levee

will prevent cars from parking on the top of the levee from station 739+00 to 691+00 increasing the views of the river, access for recreational users, and would be more consistent with setting of the Sacramento County Park.

On page 3-68 under “3.10 Land Use Planning” section “b” should be check as “Less than Significant with Mitigation Incorporated.” The current General Plan along with the DWR commitment to provide access to Sacramento River recognizes that recreation is essential for creating and maintaining healthy and vibrant communities. It provides value and quality of life to the residents and visitors of the Sacramento County region through access to both organized and informal recreational activities and services. People rely on the DWR and Sacramento’s parks and recreational facilities for the pursuit of health and fitness, self-education, connection with nature and positive social activities. Providing access to the navigable waters of the Sacramento River for recreational use defines the quality of neighborhoods and communities and provides the setting for active and passive recreation which benefits the residents of the immediate neighborhood, the larger community, and the broader region. RVWA-SIKO has been promoting this lifestyle and has been instrumental in providing safe access to the Sacramento River in cooperation with the DWR and RD341. Sacramento County’s own website promotes Sherman Island as a Mecca for a healthier lifestyle and has direct links to the RVWA-SIKO web sites. Sherman Island is a unique resource and attracts economic development and tourism to the region from all areas of the globe. The mitigation measures described herein will help to ensure that this natural resource is preserved for generations to come.

Figure 6 - Sacramento County promotes Windsurfing and Kiting


On page 3-75 under “3.14 Public Services” section “a” subsection “PARKS?” should be check as “Less than Significant with Mitigation incorporated.” As previously stated, closing down several active sailing and kiting sites including “Little Baja” will certainly have an impact on the adjacent County Park facilities just ask the Rangers. However, by keeping both “the Sign” and “the Access” open and only closing river access points on the stretch of levee from station 697+00 to 750+00 will greatly enhance the projects viability and ultimate success. On page 3-76 under “3.15 Recreation” should be completely revised. Currently this section states:

Figure 7 - Recreation section of the IS requires revisions


By stating that the project will not extend far enough into the river to require alternate access points for boaters maybe true but it does require alternative access points for kiters and windsurfers along with the many fisherman who utilize the site. The current plan will prohibit access to the river for kite and windsurf launching. Shutting down these sites “temporarily” for 2 seasons will have a significant impact on the community and the County Park. Implementing Mitigation Measures REC-1 and REC-2 previously discussed will assuage the potential impacts associated with the project. Current launches are maintained annually by RVWA-SIKO by using DWR approved Kevlar sand bags; however, each season these bags need to be maintained and or replaced at considerable time and expense. RVWA-SIKO

wants to coordinate our efforts with the planned levee improvements and requests that the following details be incorporated into the final levee plans.

Figure 8 - RVWA-SIKO Annual Kevlar sandbagging work crews

Figure 9 – Suggested configuration of Levee improvements at river access points


In summary, access to the river in this heavily used area is extremely important and alleviating the burdens that will be placed on the County Park during construction should be a top priority of the project. Maintaining the “Access” and “The Sign” launch sites during construction and restoring the existing access to the river after construction is critical. The long term considerations of recreation users on Sherman Island should also be discussed in detail. Seasonal parking, picnic areas and landscaping should be evaluated and incorporated into a long term vision for the island. Keeping traffic off the levee crown and at toe actually increases the safety of those who are accessing the navigable waters. Moving the road as far south as possible adjacent to the southern boundary of the project limits and allowing for parking between the road and the levee toe would create a much safer situation, reduce project costs, provide the DWR and the RD341 better access to the Levee slopes and crown road. This could be a DRW legacy project which enhances all of our precious resources. We look forward to the opportunity to explore these recommendations and comments in the near future and request that the comment period be extended an additional 30 days to July 23, 2014. Please provide a web site link so that we can download the current draft set of project plans and specifications which have not yet been provided. We understand that the fish release plans and specifications are currently at approximately 30% complete and the levee improvement plans and specifications are at 70% complete. Thank you for your consideration and acknowledgement of our concerns. We look forward to successfully engaging with the DWR on this project. Sincerely,

Don Ross Don Ross Vice President of RVWA-SIKO Email: [email protected] Phone: 510-750-7560 CC: RVWA-SIKO Board of Directors SFBA

RVWA-SIKO Comments for Little Baja Fish Release Initial Study-Final1

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