Series of Emails on Temporary Urgency Change (May 2011)


Note: TUCP is Temporary Urgency Change Process and TUCO is Temporary Urgency Change Order


One more response, and then I will leave you alone to enjoy your long weekend.

The flows at Hacienda last summer AVERAGED 263 CFS ALL SUMMER LONG in spite of the TUCO. The flood control management (by Army Corps of Engineers) only lasts through March or April.
Of course, we are very happy about the higher flows and hope it happens this summer as well. It’s just in drier summers the down river folks will have to suffer with bad water quality, an impaired recreation season, and suffering economy, while the urban areas use our water on their lawns and landscapes.

Have a great weekend.


On 5/26/11 7:10 PM, Phil Crader wrote:

Ms. Adelman,

I hope this explanation helps. They filed the petitions to maintain flows consistent with the BO. The order, if approved, will allow them to do that. Flows are sometimes above the 85 cfs you refer to because they are operating in a flood control capacity. When that stops, they will operate to the flows mentioned in the petition and will be required to maintain those flows, irrespective of conservation requirements. I will be out tomorrow. If this is still unclear, please consider contact Katy Washburn. You might also follow up with SCWA. I am sure they can clarify to your satisfaction.


From: Brenda Adelman
To: Crader, Phillip

Sent: 5/26/2011 6:40:03 PM
Subject: Re: Diversions and flows

Mr. Crader:

Thank you for your detailed response. I’m sorry to bother you again but I have one more question.

If there are no specific conservation or diversion requirements in this year’s Order, is it correct to assume that there are nevertheless no guarantees that flows at Hacienda, intended by the BO to be around 85 cfs, will actually be sustained at that level? While SCWA may not make releases to maintain flows currently called for in D1610 (i.e., 125 cfs), the Agency does not control all flows and the average flow at Hacienda for ALL OF LAST SUMMER was 263 cfs, a far cry from the 85 called for in the BO. Flows at Hacienda are currently around 500 cfs.

Can you send me the URL for the full report? (I got your letter today about the issuing of the Order.)

Thank you again for responding to my questions and keeping me informed.


Brenda Adelman

On 5/26/11 5:46 PM, Phil Crader wrote:

Ms. Adelman,

As I understand your email, you point out that in past orders, the Division has limited releases and restricted diversions, and are concerned that the Temporary Urgency Change Petition (TUCP) filed by Sonoma County Water Agency (SCWA) for 2011 requests limitations on releases, but does not discuss diversion amounts (as separate from releases). Decision 1610 (D-1610) specifies minimum flow requirements to be maintained via releases from SCWA.

By temporary urgency petition, SCWA is requesting that the D-1610 minimum flow requirements (minimum flows) for the Russian River be reduced to comply with the mandates of the NMFS biological opinion.

D-1610 identifies the following minimum flows in the Russian River between its confluence with Dry Creek and Pacific Ocean: (1) Normal water supply conditions: 125cfs; (2) Dry water supply conditions: 85 cfs; and (3) Critical water supply conditions: 35cfs. The water year classifications (Normal, Dry, or Critically Dry) established in D-1610 are based on cumulative inflow into Lake Pilsbury beginning October 1. In 2007 and 2009, SCWA forecast that storage in Lake Mendocino would be depleted or exhausted during the fall run Chinook migration if SCWA maintained the flow requirements specified in D-1610. As a result, SCWA requested (via temporary urgency change petition) that the State Water Board temporarily reduce the minimum flows based on water storage levels in Lake Mendocino (water levels were at 53,000 acre-feet as of April 1, 2009) to the Critically Dry flow requirements, even though inflow into Lake Pilsbury was sufficiently high to classify 2009 as a normal year.

Because SCWA requested lower flows as a result of water shortage in 2007 and
2009, it was reasonable to also require conservation in order to restrict diversions at SCWA’s downstream facilities. Permits 12947A, 12949, 12950,
and 16596 identify the downstream points of diversion and re-diversion. Copies
of these permits are available on the Division’s website for your reference. The 2007 Order required a water conservation status report. The 2009 Order also included a 25% conservation requirement consistent with the goals of the Governor’s 2009 drought emergency proclamation and Assembly Bill 32. I assume this requirement is the restriction on diversion you are referring to in your email.

In 2010, and again this year, SCWA requested that the minimum flows in Normal water years be lowered to allow them to operate to the flows mandated by the National Marine Fisheries Service (NMFS) Biological Opinion. The NMFS mandated flows are lower than the D-1610 minimum flows. The NMFS Biological Opinion mandates lower flows because of a finding that the current D-1610 minimum flows are too high.

Unlike the 2007 and 2009 petitions, water shortage did not prompt the filing of the 2010 or 2011 petitions. Though the 2010 Order did not require 25% conservation, Terms 11 through 17 of the Order require documentation of activities relating to conservation, efficiency, and best management of surface and groundwater in the SCWA service area. Similarly, though the 2011 petition does not request numeric conservation requirements, any order approving the petition would require reasonable use of water and would promote conservation, efficiency, and best management of water pursuant to the state’s 20x20x20 Water Conservation Plan (also Urban Water Management Plan; Wat. Code
§ 10608.20).

I hope this answers your question. Please feel free to call or email if you have further questions.

Phil Crader

Brenda Adelman 5/19/2011 8:42 AM
Dear Water Rights Staff:

I have a question about water rights coming out of our phone conference last week and I’m not sure who to direct it to. I request that the appropriate person respond.

The Sonoma County Water Agency’s Temporary Urgency Change Petition talks about meeting certain requirements in regards to releases from the dams and levels at the various gauges. I think I understand that part.

In our phone conference you explained to me the difference in operations in 2009 leading to very low flows. I know that Lake Mendocino was the critical issue because of relatively low levels at the start of the summer season (I believe that it started out around 65,000 AF.) The concern that reservoir levels would go too low to provide adequate flows for the fall Chinook migration lead your agency to impose a restriction on “diversions”. Apparently, while you limited releases in other years, the diversions were something different and offered another layer of control over the situation.

This is where I have a problem. I don’t see diversion amounts (as separate from releases) discussed or described anywhere in the TUCP. I had the impression that water flows into the reservoirs naturally and diversions mainly applied to the part that gets diverted into their facility at Mirabel. I know there are four diversion points, but I don’t fully understand how that works. I believe two are around Lake Mendocino, one in Dry Creek and one at Mirabel. If the dams hold back the water flowing into the Lakes, how are “diversions” being controlled? (I’ve heard the term”re-diverted” where somehow water goes back into storage, but I don’t fully understand how that works either.)

Is there a simple explanation you can provide me about this? I would like to fully understand how all aspects of controlling flow are implemented. I would appreciate your help. Thank you.


Brenda Adelman
Russian River Watershed Protection Committee