Low Flow Project becomes “Fish Flow Project”
by Brenda Adelman
Public Environmental Review Process to Begin….
SCWA is now beginning the environmental review process needed to petition the State Water Board to PERMANENTLY lower flows to 70 cubic feet per second (cfs), a 45% decrease from what is normally a minimum of 125 cfs. Decision 1610 (D1610) is the State Law they expect to alter.
In order to fulfill requirements of California and national environmental law, SCWA as lead agency is legally required to conduct a public review of their proposal. The Notice of Preparation (NOP) is the first step in this process for the newly named “Fish Habitat Flows and Water Rights Project” and was released September 29, 2010. Comments are due by Nov. 15, 2010.
The NOP document can be found at their website at: www.scwa.ca.gov/rrifr/ (section entitled “Fish Habitat Flows & Water Rights Project”: Download the “Notice of Preparation”. This is a 12 page description of the project, with map, and notice of meetings) There is an email link there for the submission of comments, (email@example.com) or comments can be mailed to: Jessica Martini-Lamb at SCWA, 404 Aviation Blvd., Santa Rosa, CA 95403.
Biological Opinion fails to address water quality impacts…..
Water quality impacts to the lower Russian River were not considered by the Biological Opinion, or in the Sonoma County Water Agency’s (SCWA) application to the State Board last spring for lowering summer flows in our area. Even so, SCWA repeatedly claims that lowered flows will benefit the fish.
Multiple agency documents consistently allude to current flows as being “artificially elevated”, but this claim does not directly apply to fish conditions in the lower river. For the entire 2010 summer, flows at Hacienda in fact averaged 263 cfs because we had a wet year, Lake Mendocino remained full and there was more water in the tributaries. Because we had a cool summer following a wet winter, the tributaries and reservoirs had much more water in them. It appears as though low flow minimums will only work in dry years, when water is scarce. Those are times when current regulations call for lowered flows already. Furthermore, for purposes of fulfilling water supply demand of SCWA contractors, flows are never viewed as “artificially elevated”.
In the Temporary Urgency Change Petition to the State, SCWA failed to consider (other than some USGS water quality studies whose results are still under wraps) the impacts on fish by either the proliferation of temperature and nutrient pollution, exacerbation of pathogen pollution, degradation of native vegetation and riparian habitat, or bioaccumulation of toxic substances. They failed to note impacts on many other bird, animal, plant, and aquatic species that call the river home. Impacts to summer recreation and the local economy went virtually ignored as well. These problems must be fully addressed before any permanent flow changes are instituted.
From “No flow” to “Fish flow”….
The short version of SCWA’s new low flow project title is called “Fish Flow Project”, as if to imply that there is some known flow that will solve the complex issues around the escalating demise of salmonid populations. For the last 30 years, we have been hearing from fishery experts that tributary habitat and ocean conditions are the prime drivers behind fishery collapse. This project addresses neither of those conditions. (Last year there were virtually no coho salmon migrating upstream to spawn in the Russian River. The Regional head of CA Fish and Game stated that he attributed the lack to ocean conditions, although he supports recommendations in the Biological Opinion.)
In regard to the new name of this project, in our view, the discarded “low flow” term carries the connotation that implies water quality impairment, which under current circumstances is probably much closer to the truth than the new name. (Low flow 100 years ago, before dam construction may have been a natural condition to which the fish adopted, but occurred long before illegal water diversions, riparian habitat destruction, wastewater discharges, gravel mining, etc. Things are much different now.)
Closed Estuary is true reason for “low flow”…
In our area, the purpose of low flow is to keep the Estuary closed all summer to ostensibly allow better breeding conditions for the Steelhead. The lowered flows are considered necessary only because there are some low-lying structures that suffer flooding when the river level goes over nine feet. For years they have artificially opened the mouth (and still do) when it reaches seven feet. If those structures were lifted or relocated, they could allow the river to get much higher and “low flow” wouldn’t be an issue. Many of us believe that keeping flows around 125 cfs, as they are now, and dealing with the flooding of properties separately, makes the most sense.
Ironically, the lowest building in Jenner is a State-owned dilapidated structure that sits in the water and floods at 9 feet. The Post Office, immediately next door, appears to be at least two to three feet higher. And in any case, most of the 2009 summer, the river remained open in spite of the very low flows.
Workshops to be held….
SCWA will hold three “workshops” to answer questions from the public about this project. We believe it is unfortunate that the format of having “stations” where one can talk one-on-one to staff, does not accomplish the intended purpose of addressing potential problems in advance, especially since no records of the conversations will be kept. The two Sonoma County workshops will be held on Dec. 4th in Monte Rio at the Community Center from 5 pm to 9 pm and on Nov. 8th at the Windsor Town Hall from 6 pm to 9 pm. Our group plans to provide sample comment letters to sign at the Monte Rio meeting.
Brenda Adelman is chair of Russian River Watershed Protection Committee and has worked on river issues for the last 30 years. She can be contacted at firstname.lastname@example.org