September 2010: Upcoming EIR & Clean Water 303(d) Listing


September, 2010

Dear RRWPC Supporter:

Summer water quality in the lower Russian River has been rapidly degrading as Sonoma County Water Agency (SCWA) wages an aggressive ad campaign to assure people that they care about the river.  Weekly ads have been promoting their efforts.

RRWPC responds to SCWA via Press Democrat Letter to Editor….
For instance, a recent Press Democrat weather page contained a SCWA ad touting the environmental friendliness of the water supply and featuring a beautiful picture of the Russian River.  The ad asserted that the Biological Opinion (BO) will save endangered fish and protect our environment.  RRWPC responded in a letter to the Editor: “They failed to mention that the BO demands a permanent 44% decrease in flows (125 cfs to 70-80 cfs) in the lower Russian River in order to maintain a closed Estuary for the Steelhead, while not flooding a relatively few properties in Jenner.” The letter continues:

“Last summer, flows went as low as 50 cfs as measured at Hacienda, although the mouth stayed open then anyway.  The canoes frequently scraped bottom, the invasive plants flourished, the algae proliferated their goopy slime in many areas.  Summer water temperatures were at levels that would kill the fish they are trying to save and, because of the low flow, it was reported that some popular beaches had more occurrences of bacteriological contamination than they had had after a bad sewer spill many years ago.

EIR for Estuary Project is imminent…
Very soon, the Sonoma County Water Agency (SCWA) will release the Environmental Impact Report (EIR) for their Estuary Project. This project will fulfill certain requirements of the Biological Opinion (BO), which includes establishment of a summer lagoon by closing the mouth of the Russian River between June 15th and Oct. 15th annually.  The goal is to create fresh water habitat for threatened Steelhead.  Saving Steelhead is a worthy goal, but the unintended negative consequences will increase water quality degradation upstream.  Furthermore, it’s very uncertain that the project can even work.

For instance, this year flows averaged 170 cfs at Hacienda most of the summer. The reservoirs and tributaries were too full for low flow to occur, though approved by the State Board, because we had had a wet winter and spring.  If low flow had been kept at required levels under these circumstances, the danger of winter floods in Guerneville would have been greatly increased!  Furthermore, since nutrient pollution is greatly increased during low flows, this year’s monitoring at higher flows will be inconclusive and unable to provide guidance regarding what to anticipate in the future.  Prior years’ nutrient monitoring had been discarded as being useless because detection limits were much too high for detecting harmful circumstances.

In the process of writing the Biological Opinion, Federal Officials had left out the impacts of their plan on water quality in the lower Russian River. They did not even consider it, since it is not part of SCWA’s water system operation.  In the lower river, the BO concerned itself with Dry Creek habitat improvements, Decision 1610 and lowering of flows, and the Jenner Estuary.  Permanent flow lowering will require changes to Decision 1610, State Law that requires an environmental impact report and public hearings to address water quality impacts resulting from new minimums.  The impacts of flow reduction will not be considered in the Estuary Project EIR, but will be considered separately, even though it is a critical component of summer mouth closure. This is unacceptable bifurcation of the process that allows for avoidance of analysis of the cumulative impacts caused by the project.  There is no other apparent reason to lower flows, other than to serve the requirements of the BO and this project.

Clean Water Act 303(d) Listings…
Every two years, the State requests evidence of water quality impairments for various creeks and streams.  As you know, RRWPC collected many pictures last year of water quality impairments in the lower river.  We did the same thing this year, although the situation was greatly altered due to much higher flows.  As we have mentioned before, the Laguna is impaired by nitrogen, phosphorus, temperature, dissolved oxygen, sediments, mercury, and in places, pathogens.  The Russian River is impaired for sediments, temperature, and in some locations, pathogens.

For the 2012 listing process, RRWPC submitted 15 pages of commentary and 25 attachments, which included 45 photographs taken in 2010, as well as our ten-page 2009 Photo Report (  We requested two new listings: Ludwigia in the Laguna (pictures indicate conditions there have become severe), and nutrients in the lower Russian River.  The State had never specifically responded to our comments on SCWA’s Temporary Urgency Petition Order (to lower flows in 2010), which included all of the arguments about nutrient pollution in the lower river.  The Order was granted, but flows were never really lowered.  The only response to comments received from the State so far was a general form letter that stated they were monitoring the situation.

The pictures submitted provide a graphic portrayal of the extent of the problem, which we believe is severe at times and in some locations.  Because there has not been a big flood in several years, the biomass from the algae at the floor of the river is getting thicker and thicker.  Some have reported that it is as much 3’-5’ deep.  Late last June, Monte Rio and Villa Grande were covered in the stuff.  There have been reports that toxic blue green algae may be present in places.  (Please email us if you know of any dogs or people having acute illnesses after contact in the river this last summer.  We were informed that the State Water Board will relay submissions to the North Coast Regional Board who will then write a staff report and respond to the comments received.  We will keep you posted on what we hear.

Nutrient pollution has many different causes with low flow providing one of the major conditions.  Other contributors are high temperatures, limited riparian, shallow channel depth, (possibly from greater sedimentation), wastewater discharges (septic and sewer systems) and re-suspension of nutrients from stirring of the sediments, etc.  It is interesting that we photographed a long unbroken line of Ludwigia from just downstream of the Russian River County Sanitation District to downstream of Northwood Golf Course.  Since flows were higher from Forestville to Guerneville, the algae and Ludwigia were not as bad this summer in those areas. Monte Rio’s flow is more under the influence of the mouth.  Since the river’s mouth was open all summer, but for one brief time, Monte Rio flows remained fairly low.  They go up during closure.  This may seem confusing, but it points out the complexities needing to be addressed.

RRWPC still needs your help!
RRWPC thanks all those who responded to our special funding appeal in July.  We had about a 40% increase in donations and funds received.   We are very grateful for your generosity.  We hope those of you who could not give last time, will be able to respond to this request.  RRWPC does not sell or loan its mailing list to anyone.

If you want to be on our list to receive information on documents, meetings, and hearings, please send an email or drop us a note with your email address requesting to receive notification and we will keep you abreast of current developments.