Russian River Estuary Project Hearing
Jan. 18, 2009
Thank you for having Board of Supervisors meeting in Jenner. It demonstrates your interest and concern about the lower river/West County community and we are grateful that you have come out to experience first hand this very incredible place.
Topics of Concern:
DEIR includes extensive use of word “natural” as in “natural environment”, implying that there was a formerly ideal state that needs to be recovered.
- There is no consistent, “natural” pattern demonstrated for mouth closings based on river flow. Documents say in some places that the mouth closes most frequently between April and October. In some places the DEIR states that it closes most frequently in April-June and September to October. For the last ten years, there have been very few “natural” closings in July and August, even when flows are less than 70 cfs.
- DEIR argues that because the project will function under a wide range of flows, it will be unnecessary to study impacts of “low flow”. During wet years, it is unclear that SCWA can control flows in the lower river at all. In fact, DEIR concluded that there was no clear relationship between river flow and mouth closures. It is more likely that ocean conditions control mouth conditions (Page 3-3 states, “…the primary factors in barrier beach formation are wave activity and tidal exchange.”)
- In order for this project to operate under all flows, it would be necessary to breach as much as 18 times a year. Breaching would disturb the seals, cost a great deal of money, and defeat the purpose of keeping the mouth closed. How would this serve as a viable way to implement the project?
Issue: Relationship of D1610 DEIR and Estuary Project DEIR:
- Estuary project is linked to “low flow” in ways that are essential to the project and environmental impacts of “low flow” as required in BO should be studied in DEIR.
- DEIR justifies not combining EIRs for two projects by alluding to their separation and sequential nature of projects in BO.
- Dick Butler (NMFS) June 22, 2010 letter that appears in DEIR states, “We believe that it is reasonable that the EIR for the Estuary Project consider the effects of flow changes associated with interim flow changes (associated with the TUC petitions) and use existing information to address the effects of these interim changes on the environment and resources such as recreation boating.”
- DEIR states that backflow from closed mouth reaches as far upstream as Vacation Beach, yet studies and impacts are only studied up to Duncans Mills for the most part, with some information given on Monte Rio. It seems you could address impacts to river at least that far apart from D1610 impacts.
- No environmental justification given in BO for meeting low flow levels at Hacienda, other than to prevent flooding at the mouth of the river.
- Only 9 properties flood at 9’ and seven of those are boat ramps and/or docks. (Why don’t properties have floating docks like many do in Monte Rio?) One property is a garage attached to a house.
- The other property is the Visitor’s Center, built on posts and piers and sits in the water with a sewer pipe going from building through water to ground. It floods at nine feet and is owned by the State. Is this adequate justification for all the damage that will be done upstream as a result of low flow?
- Page 3-8 states that 99% of the time, the water surface elevation is below 7.7’. Costs for breaching are quite high. How much money can be saved if it only occurred at 9’? (Up to 18 breachings are anticipated each year, with or without low flow.)
- The environmental costs of “low flow” must be balanced with this Estuary situation. During low flow water quality in lower river deteriorates extensively with high bacteriological readings, excessive nutrients including massive algae blooms, and extensive Ludwegia mats.
Issue: Baseline data is inadequate. Water quality in lower river and estuary a serious issue that is not adequately addressed. Furthermore, lack of baseline data in many circumstances used as excuse not to mitigate.
- Concludes that since river not listed under Clean Water Act as impaired for nutrients, current levels can serve as baseline for project as serving beneficial uses identified such as aquatic habitat and recreation. Nutrient levels can be too high for fish even though not listed as yet. Many other reasons for lack of listing.
- Data for water quality: where is it? What happened to monitoring program set up with Regional Board under TUCO? Nutrient data for 2009 deemed inadequate by Regional Board staff. Why are they not in loop?
- Massive algae blooms in parts of river during low flow. Concern about blue-green algae, which can become a problem under low flow and with high temperatures.
- 50 fish species in Estuary. If nutrient and temperature problems impair Estuary, how will they be affected? Why has Chinook fell through the cracks during the fringe seasons, such as May and June?
- Why is anoxic zone not studied for toxins? How can this DEIR avoid studies of water quality by USGS? Would anoxic conditions increase if mouth stayed closed for five months?
- What impact will a summer long closed estuary have on water temperatures in estuary? To what extent will the 6’ to 9’ of fresh water lagoon be impacted by higher temperatures? What happens to Steelhead when they are exposed to high temperatures over a long period (say 20-22 degrees Celsius)? (Guerneville averages around 23 degrees in summer.) It appears as though there is no baseline data to determine this.
Issue: Since pinnepeds leave haul out during mouth closures, what evidence exists that they won’t permanently abandon haul out that remains closed all summer?