LOW-FLOW, ESTUARY, and CEQA
January, 2011
Dear RRWPC Supporter:
Well, another year has flown by and RRWPC is about to begin its 32nd year as a nonprofit corporation. There’s a saying, “Time flies when you are having fun!” While “fun” may not be the appropriate word to describe what we do, we have certainly been absorbed and determined and concentrated on the goal of limiting some of the damage that has been continually visited on the Russian River over the years. We are grateful for your loyalty that has kept us going over time, and hope our precious relationship will continue for many years to come.
SCWA Releases EIR on Project to Control River’s Mouth
The design of structural barriers (man made dunes) to keep the river’s mouth closed all summer is the central focus of the “Russian River Estuary Management Project Draft Environmental Impact Report” (DEIR). The Board of Supervisors authorized the release of this in-house Sonoma County Water Agency (SCWA) document on December 15, 2010. Public comments are due on February 14, 2011 by 5 pm. (Please submit enclosed target letter.) A hearing will be held in Jenner on Tuesday, January 18, 2011, at the Jenner Community Hall at 6 pm (behind the fire house). Please try to attend. You can purchase a CD of the Estuary Project DEIR for $10 by contacting Jessica Martini-Lamb at: Jessica.Martini.Lamb@scwa.ca.gov
The DEIR considers several alternatives for construction of the barrier, but fails to examine impacts of the associated and required lower flows from Dry Creek to Jenner that will be studied separately, and the results of which will not released for at least 1.5 years. Furthermore, important water quality monitoring studies being conducted to study the impacts of “low flow” will not be available to even the Regional Water Quality Control Board before the closing of the comment deadline on this project.
Estuary Project and low flow must be studied together….
The California Environmental Quality Act (CEQA) requires that the whole of a project be considered in one EIR. This DEIR claims that its major purpose is to address the requirements of the Biological Opinion (BO), issued by the National Marine Fisheries Service (NMFS) in September, 2008. The BO, which has the force of federal law, requires that SCWA apply to the State for a reduction of minimum flows from 125 cubic feet per second (cfs) to 70 cfs throughout the lower river, where it is intended to accommodate the development of the closed lagoon and the avoidance of flooding in the Jenner area (NOT to save fish habitat between Forestville and Duncans Mills).
Furthermore, until a permanent flow change is authorized by the State Water Board, SCWA must apply for low flow on a temporary basis each year. These annual applications can be repeated indefinitely and are not subject to environmental review. Special water quality monitoring was required by the State Water Board as part of the Temporary Order, but in 2009 the Regional Board found the studies to be inadequate and have not been able to obtain results for 2010. It appears the State Agency in charge of water quality is getting the run around by SCWA and their Directors, the Supervisors.
Jenner properties subject to flood….
The major purpose for lowering Russian River flows from Forestville downstream is to prevent flooding of a few properties in the Estuary while still keeping the mouth closed. (Closing the mouth affects river levels as far upstream as Vacation Beach, only the DEIR only studies the area upstream to Duncans Mills.)
SCWA has historically breached (opened) the estuary at levels from 4.5’ to 9’ as measured at the Visitor’s Center, which is the lowest structure and floods at 9’. The DEIR concludes that 78 properties would be inundated at 9’, but only nine of those parcels contain structures that would be affected. Seven of the structures are boat docks or ramps and only two structures subject to flooding at 9’ are actual buildings. The preferred alternative expects to manage levels at 8’ however, so these two buildings would also not be affected. Furthermore, one of the two buildings is the Visitor’s Center, which is owned by the State and is built on piers in the water with part of their sewer pipes going underwater at about 7 feet. This would probably be illegal under today’s requirements. One could conclude then that “low flow” is unnecessary.
Uncertain correlation between closed mouth and low flows….
In August, 2009, flows at Hacienda near Forestville averaged 63 cfs (lower than the proposed 70 cfs) and yet the river mouth remained open during that entire month. In fact, over the ten year period since 2000, no matter what the flows, the mouth was breached only once each in July (2008) and August (2004). June saw four breachings (2000, 2002, 2003, 2009) over the same ten years, September also had four (2000, 2005, 2008, 2009). Most or all of those times, the mouth remained open.
In 2010, flows at Hacienda averaged 260 cfs for the entire summer period, even though the State Water Board had issued a Temporary Urgency Flow Order that called for 70 cfs at Hacienda and Dry Creek. In spite of significant reductions in dam releases by SCWA, water from the tributaries and groundwater filled the local streams and river anyway. In other words, a rainy winter and spring appears to override any manmade controls of flow. It’s possible that ocean conditions may be more responsible for the mouth’s opening and closing than river flows anyway.
Proposed lowered flows, if approved by the State Water Board, are likely to exacerbate very serious water quality problems in the lower river, particularly algal blooms. There is some concern that toxic blue green algae will take hold. Lowered flows would have a major impact on recreation and the local economy, not to mention all the other species that rely on a healthy river system to survive. Yet none of this will undergo CEQA review until after the Estuary project is approved. Please demand that both projects be considered together (Jenner Project and flow alterations). This can be accomplished by signing and submitting the target letter enclosed or writing your own letter.
Sups approve 15 SCWA projects without discussion at last meeting of year…
On December 15th, the Supervisor’s last meeting of the year, they approved fifteen Water Agency projects without discussion, although they had just spent the prior two hours honoring two departing supervisors. One of the projects had never been presented publicly before and involved trucking wastewater all over the County for irrigation and dust control. Supposedly there had been a report prepared, but no one had seen it and it was not part of the packet. The North Coast Regional Water Quality Control Board knew nothing of this and will be looking into it. RRWPC wrote a letter about our concerns, but it was ignored. We will continue to track this and some of the other 15.
RRWPC needs your help!
RRWPC will be taking on many demanding challenges this coming year. As usual, we are in need of donations of any size. 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 www.rrwpc.org. RRWPC does not sell or loan our mailing list to anyone. You are welcome to contact Brenda with questions about the DEIR at rrwpc@comcast.net.