Relief may be in sight! Thanks to the efforts of Jerry Cadagan, CalTrout, and with the support of Dan Murphy and the Audubon Society, the PUC is pursuing a more aggressive approach to stabilizing Lake Merced. Using what is called a "Categorical Exemption" under the California Environmental Quality Act (CEQA), limited amounts of water could be added to the lake this fall and winter without the need for advanced environmental review under CEQA. If the PUC proceeds under that exemption enough water could be added to stabilize the lake, and to stop its decline, until longer-term solutions can be implemented, a goal all of us support.
And while that's the good news, we remain concerned that an adequate review of potential long-term solutions is not being conducted. The PUC surprised us a few weeks ago with a full-blown study, commissioned to a consulting firm called EDAW, to determine the effect of adding as much as 10 feet of water to Lake Merced as rapidly as it can be pumped into the lake. We're pretty sure that's not a good idea, and the Sierra Club has already taken a position opposing that approach.
A community review of the EDAW proposal was conducted in mid-August, facilitated by Lisa Wayne, Chair of the Lake Merced Task Force Natural Areas Committee. A revised project plan was issued about a week later; both versions of their plan are available on the web site.
Perhaps we should get used to it, but at least we're not surprised that the major issues raised by the community were not addressed in the new project plan:
1) There is no provision for land-use assessment. Areas to be regarded as recreational to be kept free from tules, as for example the rowing docks, should be clearly identified and agreed to. Just this simple procedure would eliminate much controversy.
2) The basic hydrologic assumptions are flawed. There is repeated reference to evaluating "surface water hydrology (inflows and outflows)." Even the Scalmanini report acknowledges that the influence of surface water flows is minimal.
3) On the other hand, no provision is made for a careful evaluation, and calibration, of a model that would be sufficient for evaluating the effect of various water management policies on the aquifer, and consequently on Lake Merced. No support has been offered for the Scalmanini observation that it would take 50 years for any change in aquifer management to have an impact on lake level.
4) Similarly, no provision is made for evaluating additional aquifer management schemes. What would be the result of using recycled water to recharge the aquifer, rather than putting it directly into Lake Merced? Questions of that sort need to be addressed, and are not in this proposal.
5) Perhaps most important, the proposal contemplates only passive reaction to short-term changes in lake level. It does not consider what actions might be taken, for example in shoreline clearance to remove debris, removal of flora to prevent its decomposing as the water rises, or in reshaping the lake contours to assure additional shallow-water areas. Similarly, there is no consideration given the effect of rate of increase; what accommodation can the lake make to an increase of 6" per year over 16 years vs. a sudden increase of 8 feet?
In short, it seems that this study, whether by design or not, will lead to the conclusion that adding a large amount of water to Lake Merced is not an environmentally sound option. We need to be clear that this conclusion is valid only within the context of the study, and that no generalization may be drawn to a long-term, well managed, systems approach to restoring Lake Merced. We need to take a new look at all the issues to be sure that a coordinated approach is being taken.
I've had an opportunity to review an early draft of Katie Pilat's report, "Leaving a Lake Legacy." I'm confident that will be an important addition to our collective expertise, and a major step in the direction of providing a solid scientific base for moving ahead. We need much more of this type of effort.
Some more good news: Interest in Lake Merced remains high. A record number of guests, 4,627, visited our web site last month. Not so good: the lake level now stands at 16.2 feet, the lowest end-of-August reading since 1994, the depth of the drought.
I'll be out of the country in October, so unless something urgent comes up I'll wish you a happy Halloween now.
John
