March, 2011
Dear RRWPC Supporter:
Sonoma County Water Agency (SCWA) received 173 comment letters last month on the Russian River Estuary Project Draft Environmental Impact Report (DEIR), most expressing concerns about the project. They included letters from Monte Rio and Russian River Recreation and Parks Districts, the national environmental group Defenders of Wildlife and the Sonoma County Water Coalition, along with individual letters from many of the Coalition’s 30 member organizations. Numerous other businesses, organizations, and concerned individuals wrote also. Thanks to you all!

Sample comments…..
State Parks, who owns and operates a great deal of land around the project, expressed serious concerns about the DEIR. Their main points included:
• State Parks was not consulted in the Biological Opinion process.
• SCWA operations will impact visitor use through partial closure of Goat Rock Beach during breach events or proposed lagoon channel creation or maintenance.
• Proposed project has potential to restrict public access to Goat Rock Beach for 13.1% of days within management period during most heavily used time period.
• State Parks considers such limitations to coastal access as significant.
• The existing condition of mechanical breaching is considered the baseline. However, the breaching and resultant beach closure has not been evaluated under California Environmental Quality Act (CEQA).
• State Parks questions lack of criteria to measure project’s success or failure.
RRWPC hired attorney Michael Lozeau, California Environmental Quality Act (CEQA) and Federal Clean Water Act (CWA) expert to comment on specific issues in the document. His comments address the following allegations:
• The DEIR Improperly Piecemeals SCWA’s Adaptive Russian River Management Project.
• The DEIR’s Water Quality Analysis is Inadequate.
• The DEIR’s analysis of the existing water quality conditions in the Estuary and characterization of those conditions as “natural” is not supported by substantial evidence.
• The water quality analysis fails to address water quality in the Estuary prior to the creation of the proposed channel.
• The DEIR Fails to Identify and Propose Adoption of All Feasible Mitigation Measures Available to Address The Expected Water Quality Impacts of the Estuary Project.

Where do things go from here?
The Final EIR on the Estuary Project is expected to be out in late spring and will include all comments and consultant responses to comments. Many comments received were form letters and there will be one response for all. Sentences or segments of the document may be changed in response to comments, but major changes are usually avoided, since they would then need to re-notice and re-circulate the new document. Most of the time, we have found that the quality of responses is disappointing.

Supervisors may or may not hold a special meeting on the Final EIR sometime after that (probably within a month or two of the release of the document), but they are not required to hold such a meeting. At a minimum, they will meet on this item during their regular calendar to certify the document and probably approve the project at the same time. People will be allowed to give brief comments at that meeting, but it is unlikely that any changes will be made at that point. It would be expected that a majority of Supervisors would approve the project.
After EIR certification and final project approval, we would have 30 days to legally challenge their decision. Of course, we would have to evaluate the wisdom of that move after we have seen the Final EIR. (We do need to prepare however, by raising funds for such a challenge. We hope you can donate soon for this purpose. See below.)

The Fish Flow Project EIR addressing “low flow” won’t be out for about 16 months.
State Water Board meeting to approve Basin Plan Amendment to allow summer discharges……
By the time you receive this, we expect the State Board to have approved “low threat discharges” and “incidental runoff”. Here are some of our concerns.

For many years RRWPC has been submitting comments to the State Water Board and the Regional Board expressing concerns about their Water Recycling Policy that allows “incidental runoff” by wastewater irrigators. A committee representing many interests agreed to establish a “blue ribbon” scientific panel to determine how to monitor unregulated chemicals, including personal care products and pharmaceuticals, etc., also referred to as “chemicals of emerging concern” (CECs).

These chemicals have a strong potential for getting into the waterways through wastewater irrigation runoff. (Tertiary treated wastewater does not remove all contaminants.) It has been well documented that some can cause potential birth defects, cancer, endocrine disruption, etc. in humans and wildlife, although impacts to wildlife were not even considered. Yet, recent preliminary findings of the scientific panel called for no additional monitoring of unregulated contaminants for urban irrigation projects.

We question their findings because they did not look at synergistic or cumulative effects of multiple exposures of either the same chemical exposure or a range of chemicals. They made no attempt to address impacts from most of the 80,000 chemicals currently being produced. They did not look at impacts from bioaccumulation in soils, nor the potential for impacting groundwater quality. (Future studies may look at some of this.) They considered, but did not fully address impacts of these chemicals on infants and young people, elderly people and those with compromised immune systems.

We are extremely concerned that irrigation runoff will carry chemicals used to fertilize soil and kill bugs and weeds, such as soil amendments, pesticides and herbicides, off the site and into our impaired and highly utilized waterways. This runoff might occur in the summer when flows are low, assimilation poor, and human contact high, not to mention the prospect of further reductions in Russian River flow imminent as a result of proposed changes to Decision 1610.

RRWPC needs your help!
RRWPC needs to raise funds to prepare for possible legal action on the Estuary issue and would appreciate donations of any size for this purpose. We also have to raise funds to upgrade our website which is currently not up to date. We hope to hire a professional to set up a new site for us. We have a volunteer to provide maintenance so we anticipate that the new site would be a one-time expenditure.
Please give as generously as you can, especially if you have not donated in awhile, and also pass this information on to other interested parties. The month and year of your last donation is next to your name on the label. If you prefer donating electronically, you can access PayPal at our website at RRWPC. RRWPC does not sell or loan our mailing list to anyone. You are welcome to contact Brenda with questions about RRWPC at