Dummer v. City and County of S.F.
CourtCalifornia Court of Appeal
Date FiledMay 29, 2026
DocketA172588
StatusPublished
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Full Opinion
Filed 5/29/26
CERTIFIED FOR PUBLICATION
IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
FIRST APPELLATE DISTRICT
DIVISION THREE
TIMOTHY JAMES DUMMER,
Plaintiff and Appellant,
A172588
v.
CITY AND COUNTY OF SAN (Alameda County
FRANCISCO et al., Super. Ct. No. 23CV036826)
Defendants and Respondents.
The question presented is whether plaintiff Tim Dummer is entitled to
a writ of mandate compelling the public entity defendants to obtain an
amended water supply permit and open the Calaveras Reservoir—
immediately and in its natural state—to public fishing. Dummer contends a
writ is appropriate because defendants have a ministerial duty to act under
provisions of the Fish and Game Code, the Health and Safety Code, and
various constitutional provisions, and have failed to do so.
Our review of the relevant laws leads us to conclude that Dummer has
not established a right to mandamus relief. Specifically, he has not
demonstrated defendants’ failure to perform a ministerial duty. We will
affirm the judgment.
FACTUAL AND PROCEDURAL BACKGROUND
Plaintiff Dummer is a licensed California fisherman who has long
sought access to fish at the Calaveras Reservoir.
1
Defendants are the City and County of San Francisco and the San
Francisco Public Utilities Commission (“SFPUC”). 1 The City is the owner of
the Calaveras Reservoir, which is located in the counties of Alameda and
Santa Clara and contains fish species including resident rainbow and
anadromous steelhead trout. The reservoir provides drinking water to 2.7
million residents across several Bay Area counties and is part of a watershed
governed by the Alameda Watershed Management Plan. SFPUC adopted the
management plan in April 2001 after conducting an environmental review
pursuant to the California Environmental Quality Act (Pub. Res. Code,
§ 21000 et seq.; “CEQA”). The plan’s purpose is “to provide for improved
management of the watersheds to meet the primary goal of water quality
protection as well as the secondary goals of watershed management.” The
plan currently prohibits public access and fishing at the Calaveras Reservoir.
A. Dummer I
In 2019, Dummer filed a petition for writ of mandate seeking to compel
the City to immediately determine that public fishing would not affect the
purity and safety of the water at the Calaveras Reservoir and to obtain a
valid water supply permit setting forth the terms and conditions upon which
public fishing at the reservoir may be conducted (“Dummer I”). Dummer
raised claims under the California Constitution, the Fish and Game Code,
and the Health and Safety Code.
At the hearing on the matter, the trial court recognized, first, the public
right to fish in a reservoir is a qualified right, and second, the issue is
whether public fishing could occur in the Calaveras Reservoir without
1 Defendant SFPUC is a department of defendant City and County of
San Francisco that manages essential services related to drinking water and
wastewater. Hereafter, defendants are collectively referred to as “the City.”
2
affecting the water’s purity. Viewing the matter as not necessarily
presenting “a simple yes-or-no proposition,” the court stated the City would
need to consider a fishing program specific to the Calaveras Reservoir with
potential time, place, and manner restrictions, as well as what facilities
would be needed. The court elaborated as follows. If the City determines
that public fishing will not prevent the delivery of pure drinking water with
an appropriate fishing program in place, the City would then be “obligated”
under Health and Safety Code section 117045 to propose such a program with
an appropriate environmental evaluation under CEQA and to include
whatever program terms and conditions the City deems necessary in its
application to the State Water Resources and Control Department
(“SWRCB”) for an amended water supply permit. At that point, SWRCB will
consider whether to issue a permit with the City’s proposed terms and
conditions. 2 The court ultimately ruled the City had a present ministerial
duty to determine “whether fishing in the reservoir is something that can be
accomplished without affecting the purity of the water” provided to users, but
it emphasized the City had no other ministerial duties to perform at that
point.
Consistent with its oral pronouncements, the trial court issued an order
granting Dummer’s petition with a finding that the City had “a present
ministerial duty to make a determination as to whether fishing in the
Calaveras Reservoir can be accomplished without ‘affect[ing] the purity and
safety for drinking and domestic purposes of the water collected in the
reservoir’ under Health & Safety Code § 117045.” The court ordered the City
2 For purposes of this appeal, we accept the parties’ mutual
understanding that SWRCB oversees the water supply permit process set
forth in the Health and Safety Code statutes and regulations discussed
herein.
3
“to commence the evaluation required to make such determination
immediately,” taking into consideration “all of the variables described in
Health & Safety Code §§ 117040, 117045, 117050, 117055, 117060 and
117065.”
The City thereafter complied with the trial court’s order. In Resolution
22-0135, the City determined: “[S]ubject to the results of any CEQA review
and the analysis of the State’s Office of Drinking Water [a division of
SWRCB], . . . shoreline fishing by the public can occur under terms to be set
by [SFPUC’s] General Manager without affecting the purity and safety for
drinking and domestic purposes of the water collected in Calaveras
Reservoir.” The resolution further reflected the City’s authorization of its
General Manager “to develop the terms and conditions of a fishing program,
obtain the City Planning Department’s review of that program under CEQA;
request an amendment to the drinking water permit from the State’s Office of
Drinking Water; and present to [the City] proposed amendments to the 2000
Alameda Watershed Management Plan to allow limited public shoreline
fishing at Calaveras Reservoir.”
B. The Instant Lawsuit
After adopting Resolution 22-0135, the City started planning for a
fishing program at the reservoir. The City determined that instituting a
fishing program would require improvements designed to ensure the safety of
the public and staff, protect the watershed and drinking water quality, and
safeguard SFPUC infrastructure. Proposed improvements included widening
the existing access road to create safe travel conditions, expanding the
existing paved landing area to accommodate public parking and restrooms,
adding security fencing to protect existing infrastructure and prevent
trespass, and installing signage to direct visitors to the public access areas.
4
Upon learning the Calaveras Reservoir would not immediately open for
fishing while the City considered the necessity and parameters of a fishing
program, Dummer filed a petition for writ of mandamus and complaint for
declaratory and injunctive relief, and damages. Dummer sought to compel
the City to perform the following acts, which he contends are mandatory and
ministerial: (1) obtain the requisite water supply permit from SWRCB
pursuant to Health and Safety Code section 117045; and (2) provide public
access for fishing during open season pursuant to Fish and Game Code
section 5943 and California Constitution, article I, section 25 and article X,
sections 2 and 4. He also sought the City’s prompt performance of additional
“incidental” actions such as “consulting with agencies, developing a fishing
program (where required by law), completing environmental review or
negative declaration, amending an existing drinking water permit, and
providing correct signage regarding public access and fishing rules versus
trespass.”
The trial court denied Dummer’s petition, concluding he failed to
identify any breach by the City of a ministerial duty. In sum, the court
determined (1) the Health and Safety Code and implementing regulations
impose no mandatory time requirement for the City to submit an application
for a water supply permit; (2) the Fish and Game Code does not entitle
Dummer to immediate fishing access at the reservoir before the City satisfies
other legal requirements; and (3) the California Constitution does not impose
a ministerial duty to open up a reservoir for fishing in violation of state
statutes and implementing regulations.
The trial court also ruled the City did not abuse its discretion in failing,
at that point in time, to have applied for an amended water supply permit.
In so concluding, the court noted the City’s ongoing efforts “to address and
5
resolve preconditions” necessary to an amended water supply permit,
including a description of the terms and conditions for public fishing, a CEQA
evaluation of the anticipated fishing program, amendment of the Alameda
Watershed Management Plan, and submission of an application to SWRCB to
amend the water supply permit.
After Dummer voluntarily dismissed his claim for damages, the trial
court entered a final judgment. Dummer appealed.
DISCUSSION
A. Requests for Judicial Notice
Both sides filed requests for judicial notice, which we now address.
The City requests judicial notice of four documents filed in Dummer I:
Dummer’s petition for writ of mandate; a transcript of the writ hearing held
on November 19, 2021; the trial court’s January 21, 2022 order and judgment
granting Dummer’s petition for writ of mandate; and the trial court’s
September 21, 2022 order overruling Dummer’s objection to the return of
writ. The City also requests judicial notice of a blank “State Water Resources
Control Board, Water Supply Permit Environmental Intake Form (EIF)” and
excerpts reflecting SFPUC’s “Biennial Budget FY 2024-25 and FY 2025-25,
Water Enterprise, January 29, 2024.” Dummer has no objection to the City’s
request. We grant judicial notice of the four Dummer I documents. (Evid.
Code, § 452, subd. (d).) We deny judicial notice of the SWRCB intake form
and SFPUC budget excerpts as unnecessary and unhelpful to our resolution
of this appeal. (Jordache Enterprises, Inc. v. Brobeck, Phleger & Harrison
(1998) 18 Cal.4th 739, 748, fn. 6 (Jordache Enterprises).)
For his part, Dummer requests judicial notice of nine documents for
which judicial notice in the trial court was requested but never ruled on. The
first three pertain to orders and pleadings filed in Dummer I. The City does
6
not oppose this part of Dummer’s request, and we grant judicial notice of the
three Dummer I documents. (Evid. Code, § 452, subd. (d).)
Dummer also requests judicial notice of: a page on a website
maintained by the California Department of Fish and Wildlife providing
certain details of the Calaveras Reservoir; an online property profile for the
Calaveras Reservoir; a blank SWRCB application for domestic water supply
permit amendment; a document referencing an “indenture” between Spring
Valley Water Company and the County of Santa Clara, dated December 13,
1917; and a document entitled 2024–2025 California Freshwater Sport
Fishing Regulations, Updated September 12, 2024. We deny judicial notice of
these five documents, as they are unnecessary and unhelpful to the issues in
this appeal. (Jordache Enterprises, supra, 18 Cal.4th at p. 748, fn. 6.)
Finally, Dummer requests judicial notice of the California Fish and
Game Commission’s “Negative Declaration for Proposed Simplification and
Amendments to Statewide Inland Sport Fishing Regulations, Title 14,
California Code of Regulations” dated August 2020. (Capitalization omitted.)
Although the City filed an opposition to this request, both parties cite and
discuss the negative declaration in their briefing on appeal. We find it
appropriate to grant judicial notice of this document, as it reflects an official
act of the Commission that bears on the merits of the appeal. (Evid. Code,
§ 452, subd. (c).)
B. Standard of Review and the Applicable Statutory Schemes
The ultimate question in this appeal is whether Dummer is entitled to
a writ of mandate compelling the City to immediately apply for an amended
water supply permit and open the Calaveras Reservoir, in its natural state
without improvements, to public fishing. Dummer contends a writ is
7
appropriate because the City has a clear and present ministerial duty to act
and has failed to do so.
To obtain mandamus relief under Code of Civil Procedure sections 1085
and 1086, “the petitioner must show (1) a clear, present, ministerial duty on
the part of the respondent and (2) a correlative clear, present, and beneficial
right in the petitioner to the performance of that duty.” (Alliance for a Better
Downtown Millbrae v. Wade (2003) 108 Cal.App.4th 123, 129; see Los Angeles
County Prof. Peace Officers’ Assn. v. County of Los Angeles (2004) 115
Cal.App.4th 866, 869.) “ ‘A ministerial duty is an act that a public agency or
officer is required to perform in a prescribed manner in obedience to the
mandate of legal authority without regard to any personal judgment
concerning the propriety of the act.’ ” (Water Audit California v. Merced
Irrigation Dist. (2025) 111 Cal.App.5th 1147, 1181 (Water Audit California)
[quoting Siskiyou Hospital, Inc. v. County of Siskiyou (2025) 109 Cal.App.5th
14, 41].)
Though mandamus is appropriate to compel a public entity to exercise
its discretion as lawfully prescribed, it cannot be used to compel the exercise
of discretionary powers in a particular manner. (Water Audit California,
supra, 111 Cal.App.5th at pp. 1180–1181; AIDS Healthcare Foundation v. Los
Angeles County Dept. of Public Health (2011) 197 Cal.App.4th 693, 704 (AIDS
Healthcare).) The use of mandatory language in a statute creating a duty
does not necessarily mean the duty is ministerial; instead, “ ‘the duty is
discretionary if the [public entity] must exercise significant discretion to
perform the duty.’ ” (Mooney v. Garcia (2012) 207 Cal.App.4th 229, 233.)
Resolving Dummer’s mandamus claim requires that we interpret and
assess the applicability of various statutory and constitutional provisions,
which we undertake de novo. (People v. Blackburn (2015) 61 Cal.4th 1113,
8
1123.) However, we apply the substantial evidence standard in reviewing the
trial court’s factual findings, such as its finding that the City was engaging in
ongoing efforts to address and resolve preconditions for its water supply
permit application at the time Dummer filed his petition. (Ramirez v.
Charter Communications, Inc. (2024) 16 Cal.5th 478, 493.)
C. Statutory and Constitutional Law
Relevant here are at least three statutory schemes and their
implementing regulations: (1) the Fish and Game Code, which authorizes a
public right to access for fishing in reservoirs; (2) the Health and Safety Code,
which protects the safety of drinking water supplied to the public from
reservoirs open to public fishing; and (3) CEQA, which mandates that public
agencies assess and mitigate the environmental impacts of proposed projects.
Section 5943 of the Fish and Game Code provides the following
statutory authority for the public right to fish in a reservoir: “The owner of a
dam shall accord to the public for the purpose of fishing, the right of access to
the waters impounded by the dam during the open season for the taking of
fish in the stream or river.” (Fish & G. Code, § 5943, subd. (a).) This right is
made expressly subject to regulations of the Fish and Game Commission
(“the Commission”). (Ibid.) “[I]n connection with the duty to accord access
for fishing, section 5944 of the Fish and Game Code provides that an owner
‘is not liable in damages to any person exercising the right to fish, who
suffers any injury through coming in contact with, or tampering with, any of
the property of the owner of the dam.’ ” (State of California v. San Luis
Obispo Sportsman’s Assn. (1978) 22 Cal.3d 440, 449, fn. 7 (SLO
Sportsman’s).)
In 2020, the Commission considered the promulgation of statewide
regulations that would authorize year-round fishing at the Calaveras
9
Reservoir and other inland waters throughout California. Pursuant to
CEQA, the Commission analyzed the environmental impacts of such
regulatory changes and issued a negative declaration concluding the changes
would not have a significant or potentially significant effect on the
environment. Regulations were then adopted that define fishing methods
and gear restrictions, open season, and location and species restrictions.
(Cal. Code Regs., tit. 14, § 7.50. 3) One such regulation specifies the Calaveras
Reservoir is open to fishing all year, but only on a catch-and-release basis and
only with use of “artificial lures with barbless hooks.” (Tit. 14, § 7.50,
subd. (b)(2)(A)(1)(c).)
Meanwhile, and as a general matter, section 115830 of the Health and
Safety Code makes clear that “[a]ll water supply reservoirs of a public agency
. . . shall be open for recreational use by the people of this state, subject to the
regulations of the [State Department of Health Services].” (Italics added.) On
a more specific level, other provisions of the Health and Safety Code operate
to ensure that public fishing, as a recreational activity, may occur without
compromising “the purity of the water supplied from the reservoir to domestic
users.” (SLO Sportsman’s, supra, 22 Cal.3d at p. 452.) Health and Safety
Code section 117040 provides that a public agency “owning or operating a
reservoir used for domestic or drinking water purposes[] may open to public
fishing all or any part of the reservoir and its surrounding land.” Before
doing so, the public agency owner (“public owner”) must first “determine that
the public fishing will not affect the purity and safety for drinking and
domestic purposes of the water collected in the reservoir.” (Health & Saf.
Code, § 117045.) Once that determination has been made, the public owner
3 Unless otherwise indicated, all references to titles are to titles in the
California Code of Regulations.
10
“shall obtain” from SWRCB “a valid water supply permit setting forth the
terms and conditions upon which public fishing may be conducted in the
reservoir and on its surrounding land.” (Ibid.)
The regulations governing the water supply permit process are located
in Title 17 of the California Code of Regulations and were adopted pursuant
to the authority now found in Health and Safety Code section 115830.
(Tit. 17, §§ 7625–7627, 7629.) As a starting point, the regulations expressly
state that any “[r]ecreational use on and around a domestic water supply
reservoir is prohibited unless specifically authorized in a water supply
permit.” (Tit. 17, § 7626, subd. (a).) Where, as here, a public owner’s water
supply permit does not authorize a particular recreational use, such as
fishing, the owner must apply for a permit modification allowing such use.
(SLO Sportsman’s, supra, 22 Cal.3d at p. 451, fn. 10; see Tit. 17, §§ 7626,
7627.) Permit applications must include maps showing the reservoir area,
including the “area to be open for recreational use and location of sanitary
facilities to be provided for the public”; data on the reservoir’s size and site
topography, wind-induced currents, and other factors potentially affecting
“the quality of the stored water and movement of possible contaminants to
the water intake”; a description of “the type of recreational use proposed” and
the maximum number of persons, cars, and vehicles allowed in the area; and
a description of the public owner’s “program, personnel and financing to
control the recreational use, including maintenance and operations of
recreational and sanitary facilities, and supervision of the people permitted
in the area.” (Tit. 17, § 7627, subd. (a)(1)–(5). 4) When SWRCB finds the
4 Dummer suggests this regulation may no longer be valid because it was
authorized by statutes that were later repealed. He is wrong. As reorganized
in 1995, nearly all the repealed Health and Safety Code authority and
reference sources listed for title 17, section 7627 were reenacted with new
11
intended recreational use will not render the water supply “impure,
unwholesome or unpotable,” a “permit for such use will be issued.” (Tit. 17,
§ 7629.)
Apart from the foregoing, there may be other statutory or regulatory
schemes that are implicated in the management of watersheds that include
reservoirs or for projects proposed on watershed lands. CEQA, in particular,
embodies “California’s strong public policy of protecting the environment”
(Tomlinson v. County of Alameda (2012) 54 Cal.4th 281, 285) and must “ ‘ “be
interpreted in such manner as to afford the fullest possible protection to the
environment within the reasonable scope of the statutory language” ’ ”
(Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 511). CEQA review
appears necessary where, as here, a watershed management plan requires
amendment to allow for a new recreational activity within the watershed. In
this regard, a Health and Safety Code regulation expressly stipulates that for
“a ‘project’ as defined in Section 15378, Title 14, California Code of
Regulations[5] where environmental documentation is required, a copy of such
numbering. As relevant here, former sections 208 and 4051 of the Health
and Safety Code, which prior to 1995 were identified as statutory authority
for title 17, section 7627, are now Health and Safety Code sections 100275
and 115830, respectively. (See Stats. 1995, ch. 415, pp. 13, 505 (Sen. Bill
No. 1360).) Indeed, all the water supply permit regulations cite Health and
Safety Code section 115830 (or its predecessor) as authority. Moreover,
former section 4463 of the Health and Safety Code, which prior to 1995 was
identified as one of the statutory references for title 17, section 7627, is now
Health and Safety Code section 117045. (Stats. 1995, ch. 415, p. 560 (Sen.
Bill No. 1360).)
5 This is a CEQA regulation that defines “ ‘Project’ ” to include “[a]n
activity directly undertaken by any public agency including but not limited to
public works construction and related activities clearing or grading of land,
improvements to existing public structures, . . . and the adoption and
12
documentation shall be included in the [permit] application.” (Tit. 17, § 7626,
subd. (b).)
Finally, article I, section 25 of the California Constitution recognizes
“the right to fish” in certain waters and proclaims “no law shall ever be
passed making it a crime for the people to enter upon the public lands within
this State for the purpose of fishing in any water containing fish that have
been planted therein by the State.” The parties dispute this provision’s
applicability to the Calaveras Reservoir. (See discussion, post.)
D. Analysis
As indicated, Health & Safety Code section 117045 provides that,
before opening a reservoir to public fishing, a public owner “shall determine
that the public fishing will not affect the purity and safety” of the reservoir’s
water and “shall obtain from [SWRCB] a valid water supply permit setting
forth the terms and conditions upon which public fishing may be conducted.”
(Italics added.) Seizing on the italicized language, Dummer contends
SWRCB—not the public owner of a reservoir—is the body responsible for
determining the terms and conditions of a water supply permit. As Dummer
reads this statute, once the City determined public fishing could occur in the
Calaveras Reservoir without affecting the purity and safety of its water, the
City had a ministerial duty to immediately obtain an amended water supply
permit from SWRCB and open the reservoir, in its natural condition, to
fishing. In Dummer’s view, the City had no discretion to delay submission of
a permit application pending its efforts to consider what terms and conditions
may be necessary or convenient to the conduct of fishing activity at the
amendment of local General Plans or elements thereof pursuant to
Government Code Sections 65100–65700.” (Tit. 14, § 15378, subd. (a)(1).)
13
reservoir. For the reasons below, we cannot agree with Dummer’s reading of
the record or his view of the applicable statutory schemes.
To begin with, the City did not conclude public fishing could safely and
immediately occur at the Calaveras Reservoir without further steps. Rather,
as the record reflects, the City made a determination that fishing “can occur”
at the reservoir without affecting water purity and safety “subject to the
results of any CEQA review and the analysis of [SWRCB]” pursuant to
“terms to be set by [SFPUC’s] General Manager.”
Moreover, and contrary to Dummer’s suggestion, the relevant Health
and Safety Code provisions contain no language preempting other potentially
applicable statutory schemes such as CEQA. For instance, Health and Safety
Code section 117045 includes no language either excusing a public owner’s
compliance with other applicable laws or specifying a particular submission
timeline or deadline for permit applications. Nor does it employ phrasing
indicating it applies “notwithstanding any other law.” (In re Greg F. (2012)
55 Cal.4th 393, 406 [when Legislature intends for a statute to prevail over all
contrary law, it typically signals this intent by using such a phrase].)
By its terms, Health and Safety Code section 117045 tasks SWRCB
with making the ultimate determination of the terms and conditions to be
included in a water supply permit. However, we reject Dummer’s theory that
the statute operates to deprive a public owner of authority to evaluate—and
discretion to decide—what terms and conditions the owner deems
appropriate to propose in its application for such a permit.
As indicated, Health and Safety Code section 117045 expressly requires
that water supply permits obtained from SWRCB set forth “the terms and
conditions upon which public fishing may be conducted in the reservoir and
on its surrounding land.” Additionally, Health and Safety Code section
14
117060 authorizes a public owner to contract with other governmental
agencies and private individuals for “the construction, operation and use of
structures, facilities and equipment and the performance of services
necessary or convenient to public fishing in the reservoir and on its
surrounding land,” including structures and facilities “necessary or
convenient for the use of the public.” (Italics added.) That these statutes
contemplate discretionary action on the part of public owners is reinforced in
the regulatory permitting process.
Importantly, Health and Safety Code section 115830 makes clear that
recreational uses on water supply reservoirs are subject to the permitting
regulations contained in Title 17, which ensure SWRCB can intelligently
exercise its permitting authority. Regulations require that applications to
allow recreational uses “shall” include a host of detailed information,
including a description of the public owner’s “program . . . to control the
recreational use, including maintenance and operations of recreational and
sanitary facilities, and supervision of the people permitted in the area”
(Tit. 17, § 7627, subd. (a)(5)), as well as environmental documentation when
the program qualifies as a “ ‘project’ ” under CEQA (Tit. 17, § 7626, subd. (b)).
Since all such information and documentation must be submitted with a
permit application, the permitting scheme can only be understood as
requiring a public owner to evaluate and propose programmatic elements for
controlling public fishing in its reservoir, including those that require the
owner’s compliance with environmental laws such as CEQA. (Health & Saf.
Code, §§ 117040, 117045, 117060; Tit. 17, § 7626, subd. (b).) Critically, these
requirements enable SWRCB to make informed decisions regarding the
terms and conditions of any permit it approves.
15
Dummer also focuses on the language in Fish and Game Code section
5943 stating the public right to fish is subject to the regulations of the Fish
and Game Commission. He then highlights the Commission’s CEQA review
in 2020 that resulted in its negative declaration and adoption of regulations
authorizing year-round fishing at the Calaveras Reservoir and elsewhere.
(See Tit. 14, § 7.50, subds. (a), (b)(2)(A)(1)(c).) Dummer essentially argues
that, in view of the regulatory reference in Fish and Game Code section 5943,
the City is bound to comply with the Commission’s regulatory authorization
of public fishing at the Calaveras Reservoir without a fishing program or site
improvements. We are not persuaded.
As described in the negative declaration, the “project” reviewed by the
Commission focused on a suite of regulations that would maintain “sufficient
populations of all aquatic species to ensure their continued existence,” as
guided by goals including the maintaining or increasing of “angling
opportunity.” To accomplish this, the project specifically aimed “to increase
regulatory consistency statewide, reduce complexity of the inland sport
fishing regulations, and remove regulations that are no longer biologically
justifiable.” It was in this context that the 2020 CEQA review found “no
substantial evidence” that the Commission’s regulatory project—i.e.,
proposed changes to trout fishing restrictions such as “seasons, bag limits,
size limits, and/or gear restrictions”—will “result in a significant effect on the
environment.” But because that particular project, in and of itself, did not
require or call for any new facilities, construction, land alteration, or land use
changes, there was no need or occasion to review the environmental effects of
proposed infrastructure and facilities that might be necessary to ensure that
fishing could occur without compromising the purity of the reservoir water
and the safety and welfare of the public. We may reasonably surmise that
16
type of individualized project review was left to reservoir owners when
complying with the Commission’s new regulations, the Health and Safety
Code and its permit application process, and CEQA.
Dummer also relies on a state constitutional provision that recognizes
“the right to fish” and prohibits laws “making it a crime for the people to
enter upon the public lands within this State for the purpose of fishing in any
water containing fish that have been planted therein by the State.” (Cal.
Const., art. I, § 25.) As Dummer sees it, this constitutional provision,
together with Fish and Game Code section 5943, guarantees a public right to
fish and deprives a public owner of any authority or discretion to delay its
permit application while it considers what terms or conditions are
appropriate for controlling the conduct of fishing at the reservoir.
As a preliminary matter, we note the City contends the constitutional
provision does not apply to county-owned lands such as where the Calaveras
Reservoir is situated. But the parties’ disagreement on this point is of no
consequence, and here is why. Even assuming the constitutional provision’s
applicability, neither that provision nor Fish and Game Code section 5943
contains language purporting to guarantee an unrestricted right to fish
without regard to regulatory requirements or other important state interests,
such as addressing potentially significant environmental concerns. 6
SLO Sportsman’s, supra, 22 Cal.3d 440, provides helpful guidance on
this point. There, the trial court had entered a judgment ordering the public
entity appellants “to provide adequate public access for fishing” and “to
establish, operate, and maintain a public recreational fishing program at the
6 Indeed, had the Commission believed the Fish and Game Code and
state Constitution guarantee a public right to fish without regard to potential
environmental concerns, it would not have undertaken CEQA review of its
proposed statewide regulations.
17
reservoir.” (SLO Sportsman’s, at p. 444.) The California Supreme Court
affirmed, holding the appellants had a duty to provide “a fishing program
consisting of sanitary facilities and surveillance,” which the court deemed
necessary to fulfill the appellants’ dual obligations “to provide access to the
public for fishing under article I, section 25 of the California Constitution and
under section 5943 of the Fish and Game Code” and “to protect the purity of
the water supplied from the reservoir to domestic users” as required by the
Health and Safety Code. (SLO Sportsman’s, at pp. 452–453.) As part of its
analysis, the high court found it undisputed that the entire reservoir need not
be opened to fishing, commenting that “the nature and extent of the sanitary
facilities and surveillance that must be provided depends to a great extent on
the amount of access provided for fishing.” (Id. at p. 453; see Health & Saf.
Code, § 117040.) In that regard, the court reviewed the trial court’s approval
of a fishing program that had been proposed during the parties’ settlement
discussions and concluded such approval should not be interpreted “as
requiring any more supervision and facilities than that deemed necessary by
the State Department of Health Services to protect the purity of the water.”
(SLO Sportsman’s, at p. 453.)
As SLO Sportsman’s explains, the public right to fish “must yield in
appropriate factual situations to the reasonable exercise of the state’s inherent
police power to protect public safety and welfare.” (SLO Sportsman’s, supra,
22 Cal.3d at p. 448, relying on In re Quinn (1973) 35 Cal.App.3d 473, 486,
italics added.) And though the decision did not address the issue of CEQA-
imposed mandates, we conclude the quoted passage reasonably encompasses
not only our state’s interest in protecting water purity but also its strong
public policy of protecting the environment.
18
Dummer also claims fishing access is guaranteed under the public trust
doctrine embodied in article X, section 4 of the California Constitution, which
applies to “navigable water.” 7 The parties, however, dispute whether the
public trust doctrine applies to the Calaveras Reservoir, which is an artificial
body of water. But even assuming, solely for purposes of argument, the
doctrine’s applicability, none of Dummer’s cited authorities suggests a basis
for relief on the facts here. 8
7 Article X, section 4 of the California Constitution provides: “No
individual, partnership, or corporation, claiming or possessing the frontage or
tidal lands of a harbor, bay, inlet, estuary, or other navigable water in this
State, shall be permitted to exclude the right of way to such water whenever
it is required for any public purpose, nor to destroy or obstruct the free
navigation of such water; and the Legislature shall enact such laws as will
give the most liberal construction to this provision, so that access to the
navigable waters of this State shall be always attainable for the people
thereof.”
8 Cases cited by Dummer include Environmental Protection Information
Center v. California Dept. of Forestry & Fire Protection (2008) 44 Cal.4th 459,
515 (public trust in wildlife not violated where Department of Fish and
Game, through statutory “Incidental Take Permit” process, maintained
authority to review lumber company’s site-specific decisions regarding
preservation of owl habitat); National Audubon Society v. Superior Court
(1983) 33 Cal.3d 419, 435 (doctrine protects navigable waters from harm
caused by diversion of nonnavigable tributaries); Colberg, Inc. v. State ex rel.
Dept. of Public Works (1967) 67 Cal.2d 408, 426 (plaintiffs not entitled to
compensation for any diminution of their right of access to navigable waters
resulting from lawful exercise of state’s power to regulate such waters);
People ex rel. Younger v. County of El Dorado (1979) 96 Cal.App.3d 403, 407
(county’s “total prohibition” of rafting and boating denied “constitutional
right of the public to use of and access to a navigable stream”); and People ex
rel. Baker v. Mack (1971) 19 Cal.App.3d 1040, 1043–1044 (under Civ. Code,
§ 3479, private owners’ fencing that prevented recreational access to
navigable stream was properly enjoined as a public nuisance).
Dummer’s opening appellate brief additionally mentions sections 2 and
7 of article X of the California Constitution. But Dummer neglects to provide
any meaningful legal argument or analysis supported by case law to
19
In maintaining the City must immediately open the Calaveras
Reservoir in its natural state, Dummer further contends there are myriad
statutes providing immunity for public access to lands in their natural
condition. (E.g., Fish & G. Code, § 5944 [dam owner “is not liable in damages
to any person exercising the right to fish, who suffers any injury through
coming in contact with” dam owner’s property]; Civ. Code, § 846 [recreational
use immunity]; Gov. Code, § 831.2 [natural condition immunity].) Dummer,
however, offers no authority suggesting the immunity conferred by these
statutes either excuses the City from regulatory compliance or deprives the
City of discretion to ensure public safety and welfare through necessary or
convenient improvements to the reservoir site.
Dummer additionally argues the City’s efforts to regulate public access
at the Calaveras Reservoir and to use CEQA to delay the immediate opening
of the reservoir to fishing violates Water Code section 6026, which provides in
part: “ ‘No city or county has authority . . . to regulate, supervise, or provide
for the regulation or supervision of any dams or reservoirs in this state.’ ”
Dummer emphasizes that the Legislature, in adopting this statute, declared
its intent “ ‘to provide for the regulation and supervision of dams and
reservoirs exclusively by the State.’ ” We are unmoved.
As explained, the Health and Safety Code calls for the City’s
compliance with the regulations in Title 17, which require that recreational
uses at sites such as the Calaveras Reservoir be authorized in the public
demonstrate error based on these provisions. We need not make his
arguments for him. (Jameson v. Desta (2018) 5 Cal.5th 594, 608–609 [on
appeal, trial court’s judgment is presumed correct and appellant bears
burden to affirmatively establish error justifying reversal].) In light of the
competing public safety and welfare concerns addressed by the Health and
Safety Code and the CEQA laws, merely quoting the language of these
constitutional provisions fails to persuade.
20
owner’s water supply permit and which mandate that an owner’s permit
application include the type of information and documentation the City is
currently gathering. 9 The evident purpose of the City’s actions is to propose a
CEQA-complian