RRWPC Comments Fish Flow Project Notice Of Preparation, 11-15-10

Sonoma County Water Agency
Attn: Jessica Martini-Lamb
404 Aviation Blvd.
Santa Rosa, CA 95403

These comments are being filed before the deadline of 5 pm on Nov. 15, 2010, on behalf of Russian River Watershed Protection Committee (RRWPC). They serve as our response to the Notice of Preparation (NOP) for the “Fish Habitat Flows and Water Rights Project” or “Fish Flow Project” for short.

RRWPC standing….
RRWPC is a nonprofit public benefit organization incorporated in the State of California since 1980. Our supporters number approximately 1200 property and business owners, recreationists, and other concerned citizens in the lower river area from Healdsburg to Jenner. We also have a great deal of support from many others who appreciate our advocacy on behalf of the Russian River.

RRWPC supporters and activists utilize the Russian River for recreation and/or tourism, for fishing, swimming, for artistic expression, spiritual well being, for exercise and personal health of ourselves, family, friends and pets, and for replenishment of health and energy needed to balance out the stresses of modern day life. Due to its proximity to Bay Area urban centers, the beautiful and peaceful lower Russian River is easy to access and allows a natural refuge from everyday cares. Many of our supporters own properties in the lower river for their summer enjoyment, but reside and work in the greater Bay Area and beyond. Because of all this, they have a great interest in this proposed project.

Flawed Scoping Meeting process…..
On October 4, 2010, I sent the following email message to Ann Dubay of SCWA regarding the planned Scoping Meeting for the Fish Flow Project EIR after I learned that the “meeting” would consist of a “workshop” where there would be no presentations or Q & A with the audience. I had expressed similar concerns about this issue with the Agency about prior meetings. (See page 2 of document #6 included with these comments.) I know that people in the Russian River community want an opportunity to hear what others have to say along with the responses to their questions and a record of the proceedings.

I wrote: “I really encourage you to change your mind about the conduct of the scoping meetings. I feel that your planned format greatly diminishes interactive public involvement, and while it may be a legal way to conduct the meeting, it really doesn’t accomplish meaningful dialogue with the people who will be impacted by this project. I know citizens will be very upset, and the concerns you use to justify the format, are ironically more likely to produce the behavior you abhor. I hope you will reconsider.” (One SCWA staff person actually stated at a Contractor’s meeting that they weren’t holding a conventional meeting because they wanted to avoid citizen “grand-standing”).
The whole point of these unofficial meetings is to flush out community concerns early in the process, while workshops mostly serve the Agency’s convenience and allow them to claim that a meeting was held supposedly serving the intent of CEQA.

As it happens only about 35 citizens attended over a four-hour period (usually there is far more interest in the community on water issues). When I was there between 5:30 and 6:45, there were at least five people who came up to me and were very angry about the meeting format. I believe they gave testimony to the court reporter on hand about their concerns. I can assure you that far more than 35 people in our community are greatly concerned about this issue.

Biological Opinion assumptions….
The statement is made on page 4 of the NOP that, “Although Decision 1610 assumed that higher instream flows were better for fishery resources, information developed in the last decade indicates this may not be so for salmonid species in Dry Creek, the Russian River, and the Russian River Estuary.”

Further down the page it also says, “Specifically, NMFS concluded that the artificially elevated summertime minimum flows in the Russian River and Dry Creek that are currently required by Decision 1610 result in high water velocities that reduce the quality and quantity of rearing habitat for Coho salmon and steelhead. Additionally, NMFS concluded that maintaining these flows disrupts lagoon formation in the Russian River estuary and that allowing a lagoon to develop would likely enhance juvenile steelhead and salmon habitat.”

Supposedly these statements provide the justification for this project, yet they lump three different projects together as though they are directly connected, without describing impacts to those in between river segments affected by the project. Separate consideration is given to river flows/Mendocino dam releases that affect salmonids in the upper reaches, the Dry Creek segment that is affected by releases from Lake Sonoma and suffers most from high velocity flows, and finally, the Estuary Project, which is being considered in a separate EIR. The latter project will not address low flows called for in this bifurcated process and are being addressed as part of these proposed alterations to D1610.
There is a CEQA problem here. Because the Biological Opinion has pre-determined the options, what alternatives will/can be developed as per CEQA requirements? Representatives of National Marine Fisheries Service (NMFS) and authors of the BO have offered the alternative of a buffer “low flow” of as much as 85 cfs. That’s kind of a “red herring” however, since there are no upper limits to D1610. The Petition addresses the lowest limits to which flows can go during a “normal” rain year. (SCWA is also challenging the method for determining the basis of flow triggers, but we do not have the expertise to deal with that issue and will leave it to others to critique.)

Estuary Project, a viable alternative?
It is our understanding that the essential basis for low flow downstream of Dry Creek between May 1st and October 15th, is to keep the mouth of the river closed (by building an outlet channel after natural mouth closing) in order to create a fresh water habitat for the steelhead. Yet the mouth closed only briefly during that four-month period and when SCWA attempted to build an outlet channel or breach the mouth with bulldozers, the high swells quickly overcame their efforts. Mother Nature was clearly in charge. (See page 8 of our comments on the State Petition: #4 below) Furthermore, we wonder about the May 1st start date since the river almost always flows high through June when juvenile Chinook are still out-migrating.

Similarly the October 15th cut off date can be problematic as well. This Project expects to keep “low flow” at a time when adult Chinook salmon are migrating upstream. A September 29, 2010 article in the Press Democrat stated that three Chinook had been sited at the rubber dam. It seems as though a full discussion of low flow impacts during these migration transition times (i.e., May, June, October) would be necessary.

The question everyone is asking is: how can a permanent change to D1610 be predicated on an experimental Estuary Project? It is putting the cart before the horse. Also, there will be some years, (such as this one) when flows must be higher because of necessity due to a waterlogged watershed, and the closed mouth would probably become impossible under recent ocean conditions.

Furthermore, this Project only addresses circumstances during a “normal” rainfall year, since the current D1610 already has in place “low flow” requirements to kick in under drought scenarios. Is this project being planned for a very narrow window of multiple circumstances that might allow a fresh water lagoon to form for part of the summer? It seems as though a great deal of analysis needs to be applied to the likelihood of long-term success of this endeavor.

We question the extent to which SCWA can even control “low flow”. What seems a complicating factor is the general lack of specific knowledge about various sources and amounts of tributary stream flow ending up in the lower reaches. The whole point of this Project for our area is to keep flows low in order to allow for the construction of a barrier beach to provide a closed estuary in summer for Steelhead, while not flooding a few Jenner structures. The whole idea of implementing major changes to river flows in order to protect a few properties seems inappropriate and impractical and unfair.

The devil is in the details…..
The above statements imply that all segments of the river are affected similarly by flows. In looking at the data and various studies, we noted there are critical differences in the segments due to variable geomorphology, land use impacts, riparian vegetation, water quality influences, and other factors. To assume that adopting lower flows will address the multiple factors that negatively affect salmonid species, would be hubris.

It is essential that all factors and their unique interactions be addressed in detail so it can be determined whether and which flows are the most beneficial. There is no “one size fits all” approach to this problem. Not only do we need to know what flows are beneficial, but conversely, we need to know which are detrimental as well. This assumption that “high” flows are bad and low flows are now considered “good” seems far too simplistic for all the exigencies of a complex system.

Furthermore, circumstances can vary dramatically from summer to summer depending on whether we have had a wet or dry winter and/or spring. Most of our comments listed below address water year 2009, which was the third year of a very dry period (albeit still a far cry from critical dry years of 1977-78). Water shortages occurred throughout the Russian River Watershed. There was a sense that everyone shared the same problem. Urban areas emphasized conservation efforts (and expanded use of ground water) to compensate. Most vintners and agriculturists were forced to conserve as well, simply because of the realities of limited supply. Even wastewater for irrigation purposes was in limited supply.

Wide range of variables and complexities….
RRWPC’s comments in response to the State Board Petition (#3 below) indicated that flows for 2009 (p.9) averaged about 130 cfs for the entire period of June 1st through October 1st (June average flow: 183 cfs, July average: 95 cfs, August average: 63 cfs, and September average: 80 cfs with a total of 31 days under 70 cfs) In 2010 flows in the lower river averaged 273 cfs at Hacienda for the same period, even though a Temporary Urgency Petition had been granted by the State Water Board to maintain flows at 70 cfs as measured at Hacienda and even though releases from the two dams generally averaged around 125-150 cfs. Yet, in BOTH flow scenarios (2009 and 2010), the river mouth was open most of those four summer months.

Since the two reservoirs were relatively full most of the summer and the Army Corps of Engineers (ACOE) had to make a major release at Coyote Dam in September to avoid possible floods this winter, we have reason to believe that the watershed remained fairly saturated all summer. Additionally, we had a relatively cool summer, and water demand remained fairly low. A casual survey indicated that many local creeks had water flowing in them (more than in 2009), but not as much as might be expected. So we wonder, where is all the water coming from? Can it be that ground water sources are feeding the main stem? Is there any data on the extent ground water may be feeding the system? What needs to happen for the system to be managed to serve the needs of the closed estuary? How can low flow reliably be sustained with all the variable flow sources?

After large amounts of rainfall in winter and spring of 2010, circumstances were completely different from the earlier year, although we note that in both cases, the estuary was mostly open during the period June 1st to October 1st no matter what the flow. (A few attempts to construct a barrier beach after a brief closing met with failure. Also, conventional breachings failed as well; the ocean at Jenner has a will of its own.)

For the lower river community, the essential concern addressed in many of our comments listed below, and of critical importance to address in this DEIR, are the water quality impacts of “low flow” in the lower river. If there is a significant diminishing of water quality, as we believe we have demonstrated through our photographic report, then it may not matter what you do at the estuary, which is the “sink” of pollution occurring upstream.

RRWPC Documents addressing low flow, estuary, & water quality issues……
RRWPC’s has written several documents and/or comments this year that address portions of the Fish Flow Project and Biological Opinion calling for adjustment of downstream flows (from Dry Creek confluence to mouth and from 125 cfs to 70 cfs between May 1st and October 15th of each year). We have also commented extensively on water quality issues that will be exacerbated by this project, along with expressing our concerns about the goals of this project, in the following documents:
1. RRWPC Comments on Water Project DEIR, submitted March 10, 2009.
2. “Regarding Complaint of Friends of Eel River & Wm. Reynolds for Modification of 1905 Notice of Appropriation and License Nos. 1424, 1199, 6594 held by PGE” by RRWPC submitted to SWRCB on March 22, 2010 by Brenda Adelman.
3. Comment letter to the State Board on the “2009 Temporary Urgency Change Order” submitted on April 10, 2009 by RRWP,
4. Comment letter on the “Notice of Petition requesting modification to water rights permits for Sonoma County Water Agency by modifying the minimum instream flow requirements, Permits 12947A, 12949, 12950, and 16596” submitted to State Board and SCWA by RRWPC on May 13, 2010,
5. Protest regarding “Notice of State Water Resources Control Board, Division of Water Rights Order approving a Temporary urgency Change Petition by SCWA regarding permits 12947A, 12949, 12950, and 16596” submitted to State Board and SCWA by RRWPC on June 23, 2010,
6. RRWPC scoping comment letter on Estuary Project NOP to SCWA on June 21, 2010, and
7. RRWPC comment letter on State Water Resources Control Board (State Water Board) proposed 2010 Integrated Report, which includes the Federal Clean Water Act Section 303(d) List of Water Quality Limited Segments submitted August 30, 2010.
8. RRWPC Comments on Waste Discharge Requirements on Storm Water (Wet Weather) and Non-Storm Water (Dry Weather) Discharges from Municipal Separate Storm Sewer Systems (MS4s).
We attach all of these documents to these comments, although several have already been formally submitted to your agency along with attachments. We would like them all considered in the Fish Flow Project DEIR. One of the documents (#4 above) was a direct response to the State on this very issue (State’s Notice of Petition to Modify D1610), and submitted to SCWA at the same time. (A full hard copy with 32 attachments was submitted to your office prior to due date of May 13th.)
The concerns identified in that document are directly applicable to this Project, and should be treated as such. The points made and concerns expressed in all of these documents should be fully addressed in relation to the current project. Following is a summary of critical points in each document to be highlighted in and applied to this project.
1. Water Project DEIR Comments: important issues and page numbers related to current project:
Page 2: Claim is made that canoeing would not occur without diversions from the Eel River and summertime releases from Lake Mendocino and Lake Sonoma. SCWA has made contradictory claims in 2010 about origins of lower river flows. To our knowledge, there has never been data provided that delineates flow sources in the lower Russian River (Dry Creek confluence to Jenner).
First, there is little information about the extent to which tributary flows, or the lack thereof, contribute to downstream flows. There is little information about groundwater use and the extent to which underground flows contribute to surface flows. In general, there is need for a full study on the impacts to recreation and the local economy that would result from the lowering of flows. This is especially important during the months of July and August when flows tend to be at their lowest and recreational use at its peak.
Page 6: Incidental runoff: this issue comes up over and over again in our comments. We are concerned that wastewater irrigation programs are being encouraged by the State and pursued in our area. The new MS4 (storm water) permit and Basin Plan Amendment allows for “incidental runoff” in the summer. While they define the term pretty carefully, they do not give any recommended number and will rely on “Best Management Practices” for implementation.
Our greatest concern is the very weak oversight. Healdsburg was recently issued the first Reclamation Permit since the MS4 Permit was approved. Irrigators will self regulate up to 1000 gallon spills. We view this as problematic and far too much. It puts an implied numerical definition to the term “incidental” and may put waterways at risk. Wastewater has many unregulated pollutants and during low flow streams are far more vulnerable to toxic pollution. Because there are more people having contact with the water, health concerns are more of an issue. Also, the runoff could carry soil amendments, herbicides and pesticides into the water as well. As we will explain further on, nutrients are a very big issue as well.
Page 7: If recycled water offsets water demand and the bad economy decreases demand (including increased vacancies), and less water use results in less wastewater irrigation which results in more drawdown of fresh water sources, how might this impact low flow with less demand on the system?
Another aspect of this problem is the Agencies have far less money to deal with arising problems coming out of this situation. There will be less maintenance and less oversight that easily can result in more pollution and increased water quality problems. It’s a circular problem.
Page 11: discussion of flows. Please address issues raised.
Pages 12-13: recreation and flows. Please address issues raised.
2. Friends of Eel River Petition to State comments: The central theme of the Petition is to cease all Eel River diversions. Our response to the Petition essentially makes the case, that why we understand why FOER is taking this stand, we believe that stopping all diversions after 100 years would be too devastating to the Russian River community who have come to rely on that water. Furthermore, our analysis indicates that in dry years, diversions have already been cut by 50-60%. (see pages 5-6 of document #2) We believe that because of the bad condition of the Potter Valley Project, long range planning should begin to plan to ultimately eliminate it as a relied upon water source.
Page 8 addresses “high flows” in Russian River causing harm and why this should not apply to lower river. Please address comments.
Page 10: refers to additional water rights sought by SCWA (26,000 AF) over the past 16 years (currently on hold, but always on the back burner). Please address potential impacts to lower river if additional water rights were to be obtained.

3. Comment letter to State Board on “2009 Temporary Urgency Change Order” (TUCO) submitted on April 10, 2009 by RRWPC
Page 2 expresses concerns about the lack of oversight over agricultural water users in Russian River and tributaries and the impacts affecting Russian River flows. Please address this issue.
Page 2 (bottom) also alludes to statements that have appeared in 2009 and 2010 TUCOs regarding lack of environmental harm resulting from low flow implementation. What impacts may have occurred already by implementation of the TUCOs? What evidence has been collected assuring that no harm has occurred?
4. PROTEST REGARDING: NOTICE OF PETITION REQUESTING MODIFICATION TO WATER RIGHTS PERMITS FOR SONOMA COUNTY WATER AGENCY BY MODIFYING THE MINIMUM INSTREAM FLOW REQUIREMENTS: This document is RRWPC’s response to the State’s Petition to alter D1610 and reduce lower river flows from 125 cfs to 70 cfs between the months of May 1st to October 15th. (Please see comments above regarding flow limits during the months of May, June, and October)
We believe that all comments in this document, with attachments, and already in SCWA files, should be fully considered in regards to this project. We will not bother to go through here and point out specific issues since they are all pertinent.
We particularly want to call attention to our 2009 Photo Report, which documents excessive nutrient pollution in the lower river.
Page 2-3 (bottom/top): designated issues regarding Urgency Petition. Several of these are duplicative of others mentioned previously in this document, but should be fully addressed. We are particularly concerned about identification of current water quality problems in the lower river, including (but not limited to), nutrients, pathogens, toxins, pharmaceuticals, conventional pollutants including temperature, sediments, etc. and the impacts that low flow will have on recreation, human health, aquatic and fish survival and health, etc.
It is our understanding that USGS has been conducting a water quality study of the Russian River and that results are due at any time. We strongly recommend that all study results should be incorporated into this EIR. We also want to allude to the study of pathogens undertaken by UC Davis (on behalf of the North Coast Regional Board I believe) that should be released soon. It is my understanding that early conclusions indicate that many of the pathogens originate in the Laguna area.
The pathogen issue is a critical one for many communities along the lower Russian River. There will need to do a total daily maximum load analysis (TMDL) for pathogens and it will be critical to identify where they are coming from. Until now, assumptions have been made, probably unfairly in many instances, about septics systems causing the problem of high bacteriological counts. Ironically, some of the biggest problems have occurred in sewered areas. Also, high counts in the Monte Rio area could also be affected by winter discharges by the Russian River County Sanitation District (RRCSD), about one mile east of the Monte Rio bridge. In order for a TMDL to be affective, appropriate pollution sources need to be identified.
Page 4: monitoring program: As part of TUCOs of 2004, 2007, and 2009, SCWA was required to conduct a monitoring program to determine impacts of low flow on water quality. What were the results of that monitoring? We understand from the Regional Board that nutrient and dissolved oxygen monitoring was inadequate. I do know that the phosphorus detection limits were much too high.
It is my understanding that USGS took over this task, but results may not be known for quite some time. Will the report on that information (for 2010) be considered in this EIR? Also, it is important to note that whether it is available or not, it may not have much use in terms of knowing what impact low flow has on water quality since flows were more than twice as high this summer as they were during last, when true low flows occurred.
It is also important to note that some of the worst nutrient pollution occurred in the Monte Rio area. In fact, summer of 2010 saw some of the worst pollution we’ve seen in the Duncan’s Mills area last July. We discuss this in detail in document #7)
Low flow in relation to river mouth closing: Please address these comments.
Page 5: Please address comments on water quality.
Pages 5-6: Please address issues on algae and Ludwigia and problems with water quality monitoring data.
Page 7: Issue raised by Rick Ryan of Jenner about the impact on local water wells by this project. Please address this issue.
Page 8: What are the results of the monitoring conducted during prior “low flow” years? We are very concerned that permanent changes in flow will be authorized before necessary information about water quality impacts will be available. While a lot of testing has occurred over the years, it has often been irregular and inconsistent. Furthermore, new detection limits, new protocols and equipment provide more sophisticated information now than in the past. How can we move into the “new age” with more meaningful data on what we are doing to the water environment?
6. Scoping comments on SCWA’s Notice of Preparation of a Draft EIR for the Russian River Estuary. Since the Estuary Project will be a topic of a separate EIR, a circumstance with which we disagree, nevertheless we will not go into this in great detail. Yet closing the mouth will have a profound impact as far upstream as Monte Rio.
We have been told, and we have documented it photographically, that water levels rise as much as 5 feet (or more?) in the Monte Rio/Villa Grande areas when the river mouth closes. Thus far SCWA has refused to study the extent to which closing the mouth will affect the flooding of private properties. While most of the low-lying properties are in the Jenner area, nonetheless we believe that further study of this is necessary. (SCWA did an initial search for flood prone properties, but much more detailed information is needed.)
Page 3: Please respond to questions about water quality. (While we believe that some of this will be addressed in the other EIR, we believe that addressing this issue in this flow EIR is very appropriate.)
Pages 3-4: Please address issues around the bifurcation of the low flow and estuary issues. Also please address the experimental nature of the Estuary Project and why a permanent change to flows is appropriate in light of that circumstance.
Page 5: Please address issues raised by Prunuske Chatham Report of September 24, 2004. (This document was submitted with our Scoping Packet on Estuary NOP.) They ask the very important question: “How are the Russian River’s salmon and steelhead populations faring under the present D1610?” (We have seen SCWA fish counts at the Rubber Dam and the numbers are extremely variable and erratic year after year. In talking to Eric Larsen of State Fish and Game, ocean conditions are the dominant factor. Since no one can control the ocean, which is probably the dominant factor in all this, what are the odds that this experimental project will have any impact in the long term? Is it worth the potential and perhaps likely degradation of the river to find out?
Please address issue of historical “natural” flows as advocated by Dr. William Hearn of NMFS and the concerns we raise on this issue (and continued on page 6)
Page 6: We noted that in spite of very low flows in 2009, the river mouth was open most of the summer. That seems to belie the theory that low flows will allow for a closed mouth and conversely, that higher flows will not. If the primary factor is wave power and its impact on beach sand, how much of a role will river flow even play in this situation? It seems like the flow difference between 70 and 125 cfs is not going to make a significant difference in the long run, especially if 125 cfs cannot even be maintained in wet years. (See analysis on pages 3-4 of this document.)
Page 7: The issue is raised about the impact of global warming on future sea levels. This can have a major impact on this project and should be addressed.
7. Comments to State Board on 2012 303(d) List of Impaired Water Bodies. In this document, to which we attached over 40 pictures (most taken in 2010), RRWPC tries to make the case that the Laguna de Santa Rosa should be listed for Ludwigia and the lower river for nutrients, including nitrogen and phosphorus.
I believe that the Laguna watershed is the largest tributary feeding into the Russian River. It is also the most impaired (sediments, temperature, dissolved oxygen, phosphorus, nitrogen, and mercury). To what extent are these impairments flowing down to the Russian River? Please provide analysis. We know that Ludwigia is becoming more and more of a problem in the lower river (see photos), especially when flows are low. In fact, there seems to be a direct correlation between low flow, high temperatures, large amounts of sediment pollution and algal blooms.
Page 3: Description of 2009 Photo Report: verifies water quality issues. Please analyze the extent of the problem in the EIR and mitigations that could remedy it.
Also we begin discussion of the Laguna watershed and it’s water quality problems. We included about 40 pictures, which document the problem described. We request that the EIR address this issue.
Page 4: impacts of past wastewater discharges on water quality. What impact has this had on lower river nutrient problems and other pollutants? Please address.
Page 5: Similarly, please address Ludwigia issue in Laguna and Russian River. Also, what health issues may arise if low flow greatly contributes to spread of Ludwigia in river? (for one, West Nile Virus) Also, please address the impact on the river from the spread of Ludwigia to the Occidental Road area. This seems to demonstrate the escalating problem of the spread of this invasive weed.
It is interesting that the proposed solution for identified Ludwigia problems in the Laguna is water level manipulation. That is, they are contemplating the rise of water levels through sediment removal. How might lower flows in the Russian River impact the spread of this plant?
Page 7: here we address the over irrigation with wastewater. We mentioned this problem earlier in discussing #1, pages 5-6 of this document) In this section, we discuss the many photos we took of over irrigation in the City of Rohnert Park. We then filed a report with the Regional Board who verified that this was a violation of Santa Rosa’s Reclamation Permit. Rohnert Park had been operating under a 1993 agreement that was not being enforced by anyone until we made the complaint last year. (See enforcement letter from Regional Board.) What impact will wastewater runoff have throughout the watershed when low flow is implemented?
Page 8-9: Phosphorus study by Wickham and Rawson documents excessive contributions from Santa Rosa’s wastewater. It references important findings in the report. Please address how phosphorus contributions from wastewater discharges and irrigation runoff has and will impact the lower river during low flow periods. While we realize that actual discharges occur only in the winter, nevertheless, nutrients bind up with the sediments and can be re-released into the water column when disturbed (as with recreational activities).
Page 10: 2010 inability to implement “low flow” because of excessive water in system. Also, Biological Opinion’s limits in addressing water quality impacts of low flow. Please address issues raised.
Page 11: Photos of algae demonstrate correlation between low flow and algal blooms. Also, we provide photo evidence in “Report” of change in water elevation in Monte Rio with before and after pictures within one day of opening mouth.
Blue green algae: we have had conflicting reports about whether there is blue green algae in the river as per discussion on pages 11-12. Nevertheless, we encourage you to address this issue. If low flow becomes a reality, we believe it should behoove SCWA to do extensive monitoring and testing for this toxic plant. We looked into doing it ourselves but found there are only a few labs in the nation that test for this toxin. Since it is such a serious health issue, we hope it will be vigorously addressed.
Page 12: here we give details on the algae problem in the Monte Rio area that we alluded to earlier in this paper. Also, we would like information on contributions of nutrients (and Ludwigia) from RRCSD discharges and golf course irrigation. Please address this issue.
Page 13-14: here is a description of former conditions by a long time river resident, Gary Getchell. Please describe how low flow will impact the degradation he mentions.
8. Waste Discharge Requirements on Storm Water and Non-Storm Water Discharges from Municipal Separate Storm Sewer Systems: RRWPC Comments July 5, 2009
Page 3: description of problems with urban runoff. RRWPC is concerned that next year Santa Rosa will implement an extensive pilot irrigation project. The Regional Board has implemented the MS4 permit that allows for “incidental” runoff. (See earlier discussion in this paper on pages 5-6)
Page 4: here we delineate the discrepancy between regulation and enforcement. Unfortunately the best intentions result in water quality impairments if not adhered to. Please address this problem in relation to low flow.
Pages 5-6: Please address issue of agricultural runoff and lax enforcement of farm ponds in relation to human health and low flow. This is of especial concern when no one has any money.
Pages 8-9: Please address issue of unregulated chemicals in wastewater and impacts when it runs off into low flow streams. What testing has been done in the river to determine whether toxins mentioned on page 9 are present in the Russian River and what impact low flows will have if they are?
Pages 9-10: Please address the impacts from the various circumstances mentioned in regards to low flow and water quality.
In general, we request that the EIR address the issue of very limited funds for conducting programs such as the Estuary Project. What happens if the project cannot proceed, but low flow is implemented anyway? Please describe how State Agencies are affected in their ability to oversee implementation of the low flow project.
We are running out of time, and other than the eight described attachments, we will only add the pictures from #7. Since you already have documents and packets for numbers 1, 4, 5, and 6, we assume that we don’t have to resubmit all of the attachments to those documents. Please let us know if you do want them re-submitted.
There is a great deal more we can add here, but there will be further opportunities during the DEIR review process. We hope you will be able to address our comments here in the DEIR. We also urge you to have a regular meeting for the EIR hearing process. We can assure you that the community has great interest in this project, even though not many attended your recent “workshop”.