RRWPC Response to Dr. William Hearn’s Article
In Sonoma County Gazette on 6-3-10
By Brenda Adelman for Russian River Watershed Protection Committee
June 7, 2010
ONE THING WE SHOULD BE LEARNING FROM THE BP OIL SPILL DISASTER IN THE GULF OF MEXICO IS THAT ALL NEW TECHNOLOGIES HAVING THE POTENTIAL FOR CAUSING HUMAN AND ENVIRONMENTAL HARM OR AFFECTING BENEFICIAL USES, SHOULD HAVE AN EXIT PLAN FOR WHEN THEY GO AWRY.
• THE PLAN SHOULD BE FULLY VETTED BEFORE ANY CONSTRUCTION AND/OR IMPLEMENTATION OCCURS;
• PENALTIES FOR FAILURE SHOULD BE COMMESURATE WITH THE EXTENT OF THE HARM AND,
• ALL WHO SUFFER SHOULD BE FULLY COMPENSATED.
• IN THE CASE OF ENVIRONMENTAL HARM, APPROPRIATE SUMS OF MONEY SHOULD BE ASSIGNED TO THOSE WHO WORK TO RECTIFY THE PROBLEMS THAT RESULT FROM THE FAILURE OF THE PROJECT.
The Biological Opinion has proposed an experimental project to possibly improve habitat conditions in the Russian River Estuary for the endangered Coho and threatened Steelhead. This experiment will last about seven years, after which it is assumed that recommended features of this proposal will become permanent. The main thrust of this experiment is to lower flows to allow for a closed Estuary every summer, while not flooding a relatively small number of parcels in Jenner. Few options are proposed for accomplishing this task and alternative flows are not being considered. We are greatly concerned that water quality will deteriorate as a result of this project.
As lead author of the National Marine Fisheries Service’s Biological Opinion, Dr. William Hearn wrote a lengthy article in the Sonoma County Gazette in the June, 2010 issue, defending the Agency’s requirement to maintain low flows in the Russian River between May 1 and October 15, 2010 and all future years. RRWPC also wrote an article in that Edition, but did not see Dr. Hearn’s article until the paper had been published. This is our response to his comments.
Restoring a more natural flow….
In order to promote the recovery of Coho and Steelhead, the article notes that federal officials recommend, “One of these steps involves restoring a more natural flow regime for the Russian River, while being careful to not unduly impact water quality and other resources.”
The article refers to possible pre-dam river flows of 30 cubic feet per second (cfs), but is unclear about whether these flows occurred throughout the river system. The article fails to assign impacts from all the changes in land use that has occurred in the last 100 years, nor how going back to original flows, would impact the entire system. In fact, it is stated that Estuary rearing would help the survival of the species, but fail to mention that normal habitat in the tributaries has been decimated by legal and illegal water diversions, careless agricultural processes, timber harvesting, gravel mining, etc. Now they are left with fewer habitat options, and this scheme is an experiment and possibly a last ditch effort, to save species that may not have a chance otherwise.
Actually, when they talk about going back to “natural flows”, they are only recommending such flows for the lower river and not the entire system. Flows north of Healdsburg will only be reduced to 125 cfs (which is our normal flow and with which we could easily survive). By assigning a theoretical historical flow of 30 cfs and then appear generous by saying they will allow us three times that amount, is manipulative and condescending and certainly not at all scientific.
Furthermore, they state that while normal low flow had been 125 cfs, ACTUAL flows commonly ran 120 to 180 cfs, therefore “low flow” should be 70 to 85 cfs. There was no data provided demonstrating how the 70 cfs was arrived at.
The phrase, “not duly impact water quality” has not been defined and no specific regulatory standards are offered. It merely states that the Regional Water Quality Control Board provided oversight on water quality monitoring. Yet, nutrient monitoring conducted last year incorporated excessive detection limits, which resulted in worthless data. Temperature was extremely high, but no concern expressed. Our impression is that the Regional Board actually paid little attention to this process.
A photo project of the lower Russian River all last summer documented extensive amounts and a large variety of algae and invasive Ludwigia. This problem has not been quantified and we are hopeful that the photographs will provide evidence to the State that validates our concern. Dr. Hearn’s article sloughs off the problem by stating that nutrients and pathogens are the result of failing septic systems in the lower river, while providing absolutely no scientific evidence to that effect. Actually, there is a report that will soon be released out of UC Davis indicating that a significant amount of pathogens in the Russian River come from the Laguna. It is obvious to all that much of the nutrient pollution does as well.
Furthermore, the article fails to mention that there is no baseline data for toxins, nutrients, and sedimentary loads. In fact, to our knowledge there is little of value being collected on these and unregulated chemicals in wastewater discharges are also being ignored. Furthermore, it does not appear that toxins in the Estuary dead zone are being tracked either. While stating that there is no concern about wastewater discharges since they only occur in the winter, they do not consider that nutrients and pathogens from discharges reside in the sediments in the summer and get released into the water column when they are disturbed. And, no alternative plan is provided should harmful water quality impacts from low flow be discovered in the interval.
Low Flow to Allow Barrier Beaches to Form Lagoon in Estuary……
Ocean waves push the sand to form barrier beaches, which in turn, during low flows, cause the river to close. Except for extreme drought years, the mouth has usually been open during the summer over the last 100 years. NMFS attributes this to the high summer river flows. The Biological Opinion assumes that low flows will keep the mouth closed, but fails to consider a possible raise in sea level resulting from global warming. In other words, this whole experiment may be doomed to failure because of future conditions that have not been considered. (And here we come back to BP!)