Comments on Regional Water Board’s Integrated Plan


At the last Regional Water Board meeting – when Flow Impairment was being considered as part of the listing process – the Board recognized that there was a serious problem with flow impairment with our surfaces waters – but – could not justify allowing for Flow Impairment to be a factor necessitating such listing.

The basic argument was  that  “Listing….seems a clunky way to get at the issue.”

The following poses the question of “Clunky-ness” as an inherent aspect of all Regional and State Board programs and policies.

Glunky?  What program do they have that is not “Clunky”?

Dealing with the subject of Low Flows via a listing might seem “clunky” – what other avenue are they suggesting we use.

Are listings for Temperature, Sediment, Nutrients, Pathogens not “clunky”

Are ineffectual Implementing Programs, that lack enforceability (due to lack of clearly stated operational standards – Dairy WDR, Timber WDR, still to be developed WDRs) not “clunky”.

What can be clunkier than a bunch of rivers with no water in them?

Everything is “clunky” – as we are dealing with messy situations.

Listing merely points to the problem the needs attention and remedy.  How you deal with the problem may or may not be “clunky”. – depending on authority and design.

Listing  merely tells responsible agencies and planning authorities that they must look at issue and address it.

When a program or policy to deal with flow issues is derived that is not “Clunky” -  I will eat my hat.



To All,

I want to support Alan’s concerns about the flippant use of the word ‘clunky’ to describe your decision to NOT list flow as a water quality impairment.  The use of that word totally lacks credibility, scientific basis, and does nothing to ameliorate our extraordinary water crisis taking place in all our rivers.  The use of the word ‘clunky’ is of particular concern since Matt himself talked about the causal role of flow in the extensive nutrient impairment of the Klamath River earlier in the meeting on the day you made your determination.  We have three endangered fish species at risk here, the livelihoods of major agricultural operations, a very popular recreation area, all of which represent huge amounts of tax revenue for the State, not to mention the incredible environmental values that living in our area brings to all of us.  We need a much more serious justification for NOT listing this critical element as an impairment.

I want to acknowledge that this is a very thorny and controversial issue. You have limited resources to address flow impairments, but that has never been a cause to stop critical listings before, that I am aware of.  In fact, how many of the listed impairments were supported by past Boards, in spite of complaints they would be too costly for regulated entities to comply with?

Those of you who are current members of this very important Board are intelligent and knowledgable people who were placed in your position because you know far more than the general public about technical and legal aspects of water quality and river functioning.  Your justification for not listing flow as an impairment is very disappointing.  We request that you provide a scientific basis for why it is NOT necessary to place ‘flow’ on the 303(d) list.

Finally, justifications provided thus far are not consistent with many other impairments listed in the past, as Alan points out.  Unless and until the listing occurs, you would be under no obligation to fully address its impacts let alone how you will protect beneficial uses without it.


Brenda Adelman

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Sonoma County’s Riparian Corridor Ordinance

Mark your calendar & spread the word:

Planning Commission hearing
August 28, 2014 at 1:00 pm
PRMD hearing room

Board of Supervisors hearing
Oct. 21, 2014 (tentative)
Nov. 18, 2014 (tentative)
Supervisors’ Chambers
Sonoma County Administration Building
575 Administration Drive, Room 102A

Be sure to let others know about these important hearings.  Our voices will be needed to inform and encourage good decisions.

have a great week,

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Governor Brown signs tunnels-enabling water bond

Governor Jerry Brown signed legislation Wednesday evening to put a controversial $7.5 water bond before voters this November.

Dan Bacher, August 2014

The Legislature passed the water bond, strongly opposed by family farmers, Delta residents, Tribal leaders, fishing groups and majority of the state’s environmental groups, in spite of an intensive campaign to get key legislators to vote against it.

The water bond will facilitate the construction of the most environmentally destructive public works project in California history, the $67 billion peripheral tunnels, under the ironically named “Bay Delta Conservation Plan,” according to Delta advocates.

“Water is the lifeblood of any civilization and for California it’s the precondition of healthy rivers, valleys, farms and a strong economy,” gushed Governor Brown. “With this water bond, legislators from both parties have affirmed their faith in California’s future.”

The legislation signed by Governor Brown, AB 1471 by Assemblymember Anthony Rendon (D-Lakewood), replaces the current $11.1 billion water bond on the November ballot. The bipartisan legislation passed the Senate 37-0 and the Assembly 77-2.

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Delta tunnels bad news for salmon industry

Taxpayers, anglers would suffer most 

August 08, 2013
Guy Carl

A hot topic in the California Legislature these days is the “peripheral tunnel” project designed to divert water to southern California farmers and cities.

This project is strongly opposed by many salmon advocates and other environmental groups due to the further harm it would inflict on the already embattled Sacramento-San Joaquin Delta system.

The project consists of twin tunnels that would capture water from the Sacramento River system in the north, send it underground beneath the natural Delta waterways, to then be deposited into the existing south Delta pump system. From there the water flows away from the Delta to serve southern California water users.

The tunnels are the centerpiece of the proposed Bay Delta Conservation Plan (BDCP), which is described by supporters as “a collaborative effort by government officials and water contractors to solve California’s water problems.”

The stated objective as defined by the California Legislature is to achieve two goals — providing a more reliable water supply for the State of California, and restoring the Delta ecosystem.

Supporters of the environment see it instead as a water grab disguised as a conservation plan.

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Posted in Environmental Impacts, Salmonid/Wildlife Impacts, Streams and Wetlands Impacts, Water Conservation Issue | Leave a comment

Legal Challenge to Industrial Printing in the Coastal Hills

The Scott River in Siskiyou County

All that you see in this aerial view taken in the coastal hills of western Sonoma County was built without a General Plan Amendment and the required Environmental Impact Report. This industrial land use is unrelated to our local agriculture or natural resources and defies our General Plan.  A major expansion of this printing factory, Dharma Press, was recently narrowly approved by the Board of Supervisors with a special exception for a charismatic religious use.

Under the cover of a religious retreat, Dharma Press has moved its entire printing factory from an industrial section of Berkeley to the coastal forest and is now producing over 400,000 books annually there. Ratna Ling Retreat and Dharma Press pay no taxes, nor do they provide jobs to local residents, but they threaten our safety with highly combustible, dense-volume paper storage warehouses in a forested area, and burden our fragile, narrow roadways with 40-foot tractor trailers daily. Many of these books are sold commercially for profit.

This is an important land-use issue that will set a precedent for similarly zoned parcels in Sonoma County. Say yes to preserving our General Plan and rural coastal hills and no to unrelated and unregulated industry in our Resource and Rural Development areas.

Coastal Hills Rural Preservation filed suit July 24 in Sonoma County Superior Court to stop the expansion of Dharma Press at Ratna Ling Retreat (35755 Hauser Bridge Road), an industrial-scale printing and storage facility in an otherwise rural area of the Cazadero hills above Salt Point State Park.

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Press Release: West County Residents File Lawsuit to Halt Industrial Development in Coastal Hills

A group of West County residents filed suit Thursday in Sonoma County Superior Court to stop an expansion of the Ratna Ling Meditation Center that would put an industrial scale printing and storage facility in an otherwise rural area in the Cazadero hills.

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The lawsuit contends that the Board of Supervisors’ June approval of the 60,000 square foot printing facility is not consistent with the County’s General Plan and zoning ordinances, and opens the door to other industrial uses in the County’s rural areas. This decision is particularly egregious given the project is located in a remote, coastal woodland area, susceptible to wildfires, with limited access along a one-lane, twisting road, and far from fire services. Fire Chief Michael Singer was unequivocal at the Board of Supervisor’s hearing, stating, “The Timber Cove Fire District does not now have either the equipment or the ability to fight Industrial Fires. The current conditions of the proposed use permit are inadequate to protect the people, property, and natural resources of this District.” The lawsuit asks the court to order Ratna Ling, a Buddhist retreat, to prepare a full environmental impact on the consequences of the project, including a complete analysis of fire danger. The suit states that the project is inconsistent with the General Plan, the Hazard Management Plan, and that the county authorized activities where impacts were not adequately examined.

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Russian River Low Flow Curtailments Considered at CDFW Meeting

To All,

This article on low flow closures was published by the Ukiah Daily Journal on July 27, 2014.


The California Department of Fish and Wildlife will hold a public
meeting Thursday to discuss a proposed low-flow closure change to the
Russian River and North Central Coast streams.

The Gualala Community Center on Center Street will host the meeting
July 31, from 3 to 6 p.m.

Fish and Wildlife staff will spend time discussing the regulation
change proposal, and then those in attendance who wish to comment will
be allowed to do so. A final recommendation will be made to the Fish
and Game Commission at a meeting in Van Nuys in December, according to
a CDFW press release.

The proposal is to add a low-flow fish restriction to the Russian
River because of the impact of drought conditions to local fisheries
that have occurred in recent years, the press release stated.

The river is the habitat of coastal Chinook salmon, Coho salmon and
Steelhead trout. All three fish species are listed under the federal
Endangered Species Act, while the Coho are also listed under the
California ESA, the press release stated.

“We are trying to bring the Russian River in line with other coastal
streams who have low-flow closures,” said Ryan Watanabe, fisheries
biologist with Fish and Wildlife.

After the past two winters, the department has found the salmon
entering these streams were forced to congregate in larger bodies of
water within the rivers. The concern is that fishermen could easily
harvest the congregating fish out of the deeper areas of the
waterways, according to the press release and proposed emergency
regulatory action by the Fish and Game Commission.

Also, there is an expected decrease in fish eggs and younger fish
within these systems as drought conditions continue to have an impact,
according to proposed emergency regulatory action by the Fish and Game

Russian River and North Central coastal streams have remained open to
fishing after an emergency closure, that was enacted by the Fish and
Game Commission in February, expired at the end of April, according to
the press release.

“We are early in the regulation process,” Watanabe said. “This will
probably be like a year process, so the sooner we start, the sooner we
can get regulations in place.”

Adam Randall

Written comments may be sent by email to, or by mail to CDFW, Bay Delta Region,
Attn. Ryan Watanabe, 5355 B Skylane Dr. Santa Rosa, CA. 95403.

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State issues new water curtailment orders, plans swifter crackdown on diversions


July 3, 2014

The Russian River, dry lakebed of Lake Mendocino, Friday Jan. 31, 2014

The Russian River pitches and yaws in to the dry lakebed of Lake Mendocino, Friday Jan. 31, 2014 in Ukiah.  (Kent Porter / Press Democrat)

State officials on Wednesday issued new water curtailment orders to thousands of users and adopted emergency regulations that allow them to more quickly crack down on people who ignore orders to stop diverting water from drought-stricken rivers and streams, including the upper Russian River.

“Water rights holders who fail to comply with the regulations face immediate fines or administrative actions,” state Water Resources Control Board officials said in a news release.

The action, which included the approval of fines for noncompliant users, came on the second day of board discussion about drought-driven regulations.

During the public hearing the day before, some water users voiced strong objection to the new regulations, particularly measures that allow the state to fine noncompliant users up to $500 a day without a hearing. Those cited can ask for a hearing after they’re fined.

“Due process doesn’t mean you shoot the person and then give them a trial,” said Robert Mehlhaff, general counsel at Naglee Burke Irrigation District near Tracy, the Sacramento Bee reported.

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Obama Administration Agrees to Stronger Protections for Salmon From Pesticides

Fishing and conservation groups praise stronger stream buffers from toxic sprays

This is a huge step forward for the health of our rivers and salmon fisheries. Before this agreement, we lacked effective ways to keep these poisons from entering our rivers and streams. EPA and the Fisheries Service can now continue to work together toward permanent protections that keep pesticides out of our waters. Steve Mashuda, Attorney, Earthjustice June 4, 2014

A coalition of advocates for alternatives to pesticides, conservation organizations, and fishing groups have reached a significant agreement with the Environmental Protection Agency (EPA). The agreement restores reasonable no-spray buffer zones to protect salmon and steelhead from five broad-spectrum insect killers-diazinon, chlorpyrifos, malathion, carbaryl, and methomyl.

“We know our Northwest farmers and growers to be good land and water stewards. In reaching agreement, EPA will now give clearer direction to farmers on how to better protect fish, if and when they choose to use these chemicals near salmon-supporting streams,” said Kim Leval, Executive Director of the Northwest Center for Alternatives to Pesticides (NCAP), the lead plaintiff on the lawsuit that led to the settlement agreement. “We know, for example, that many fruit growers in the Columbia Basin have already implemented larger buffers with assistance from public and private funding sources. NCAP is committed to working in partnership with affected farmers to develop and implement alternatives to the five insecticides.”

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DWR’s updated Groundwater Information Center

I thought this might be of interest.

have a great week,


If you haven’t had a chance to view DWR’s updated Groundwater Information Center, please click on the following link:

On the site are links to all of the available Groundwater Management Plans (grouped by Hydrologic Region), as well as groundwater level change maps (Dot Maps) for numerous time periods in the Groundwater Data Reports section.  Plus lots of other groundwater-related information, such as the Drought Response report that was published on April 30th; a revised report is being prepared for October 2014.

Also, just last week, DWR made publically available an Interactive Map of Groundwater Information and Data.  For this first release, the contour and color ramp options are limited to the Central Valley, but DWR is working with various local agencies to qualify well data so the contouring and various analysis tools can be expanded to other basins throughout California.  As more data becomes publically available through the CASGEM Program, this will be easier to accomplish.  You can currently view Change in Groundwater Level data for the Sonoma area through Spring 2014.

If you have any comments about the site, feel free to let me know and I’ll forward them on to the developers.  Hope this is helpful as you work towards sustainable groundwater management in your area.

Thanks, Mark.

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