Archive for the 'Streams and Wetlands' Category

CA Water Board Slams Klamath Dam owner’s Application for Clean Water Permit

by Dan Bacher September 30th, 2008

State Regulators today announced a plan to evaluate the impacts of dam removal on the Klamath River, but not PacifiCorp’s own proposal for operation, according to a joint news release from the Karuk Tribe, Klamath Riverkeeper and the Pacific Coast Federation of Fisherman’s Associations.

Dam removal is urgently needed as West Coast salmon populations are in their worst-crisis ever. Salmon fishing in ocean waters off Oregon and California and the Central Valley rivers is closed for the first time in history this year, due to the collapse of the Sacramento River fall chinook salmon run. However, commercial fishermen suffered from severe restrictions off the California and southern Oregon coast two years ago, due to the dramatic decline of Klamath River chinooks. We must restore the salmon runs of both the Klamath and Sacramento rivers so we don’t suffer from more fishery failures in the future.

KARUK TRIBE · KLAMATH RIVERKEEPER · PACIFIC COAST FEDERATION OF FISHERMAN’S ASSOCIATIONS

P R E S S   R E L E A S E

CA Water Board Slams Klamath Dam owner’s Application for Clean Water Permit State Regulators announce plan to evaluate impacts of dam removal but not PacifiCorp’s own proposal for operation

Sacramento, CA - Today the California Water Resources Control Board released the Notice of Preparation of an Environmental Impact Report on Oregon based PacifiCorp’s proposed relicencing of Klamath River dams. The Water Board will not evaluate PacifiCorp’s own proposal for a status quo dam license which they describe as “not legally feasible” due to federal agencies’ mandatory prescriptions for fish ladders and other mitigation measures.

“PacifiCorp is playing the delay game by repeatedly withdrawing and then re-filing to same illegal plan,” commented Glen Spain of the Pacific Coast Federation of Fishermen’s Associations (PCFFA), a major fishing industry group. “But every day they delay kills more fish, and this has got to stop. Dam removal is the only viable option, and until PacifiCorp gets serious about a dam removal plan we can support, this process must move forward toward dam removal with or without them.”

Instead of analyzing PacifiCorp’s proposal the Water Board plans to consider the following four alternatives: · FERC staff recommendations plus incorporation of the federal agencies mitigation measures including construction of fish ladders

  • Removal of Iron Gate and Copco 1 dams
  • Removal of Iron Gate, Copco 1, and Copco 2 dams
  • Long Term Modifications stemming for a potential settlement agreement among Klamath Basin stakeholders including PacifiCorp

Currently, Federal, California, and Oregon officials are negotiating an agreement to remove the dams with PacifiCorp, however, Tribes, fishermen, farmers, and environmental groups have been excluded from the talks.

“Without the participation of the people that live, work, and raise families here on the River, we have doubts that a meaningful agreement will emerge from these talks,” said Craig Tucker, spokesman for the Karuk Tribe. Tucker adds, “the Clean Water Permitting process is critically important. If the Water Board finds that PacifiCorp can’t meet California’s clean water standards with the dams in place, they can’t get the dams relicensed.”

The Federal Clean Water Act gives states the authority to regulate dam owners according to their own clean water standards. PacifiCorp’s Klamath dams create massive blooms of toxic blue-green algae that lead state and tribal agencies to post warnings against contacting the river and reservoirs each summer. Earlier this year, the Environmental Protection Agency listed the Klamath River as “impaired” by the toxic algae.

Economic reports from the California Energy Commission as well as FERC conclude that dam removal is actually cheaper for ratepayers than the construction of fish ladders and mandated increases in river flows. Even if the California Water Board issues a Clean Water Permit to PacifiCorp, it will most likely come with another set of mandatory mitigation measures which will drive the cost of relicensing up even more.

According to Klamath Riverkeeper’s Malena Marvin, “these dams are a money pit for rate payers and a death sentence for fish. It’s time for Warren Buffett to tell PacifiCorp to solve this problem by negotiating a dam removal agreement with the Tribes, fishermen, and farmers that live in the Klamath Basin. If he doesn’t he will go down in history as the man who brought poverty, disease, and toxic pollution to one of America’s greatest watersheds.”

For more information: Craig Tucker, Spokesman Karuk Tribe 916-207-8294 Glenn Spain, PCFFA, 541-689-2000 Malena Marvin, Klamath Riverkeeper 541-821-7260

Santa Rosa’s IRWP update

Incremental Recycled Water Program (IRWP) Update
October 6, 2008

Information about the Seasonal Storage Project (SSP) and the availability of the Final EIR follows below.

The SSP Final EIR is available for review, today, October 6. Available online at www.SRCity.org/SeasonalStorage under Studies & Reports.

The Board of Public Utilities (BPU) meeting at which certification will be considered is being held at 5 PM* in the Santa Rosa Council Chamber, 100 Santa Rosa Avenue, Santa Rosa.
(*Note meeting time change to 5 PM) Confirm agenda and schedule at http://www.SRCity.org/BPU.

Where you can find copies of the SSP FINAL EIR:
The Final SSP EIR (as well as the Discharge Compliance Project EIR) will be available for review at Sonoma County Branch Libraries in Santa Rosa, Rohnert Park/Cotati, Sebastopol, and Windsor and on the project Web site at www.SRCity.org/IRWP.

The Final EIRs, appendices and reference material cited in the Final EIRs will also be available for review at the Laguna Plant Library, located at 4300 Llano Road, Santa Rosa. Hard copies and CDs of the Final EIRs will be available for purchase by calling ARC at 707.579.9096.

If you have any questions please call 707.836.0300.

Mark Millan
Public Information Coordinator
www.SRCity.org/IRWP
707.836.0300

Russian River Biological Opinion Summary

Dear Friends:
The National Marine Fisheries Service (NMFS) has just released the final Endangered Species Act (ESA) Section 7 Russian River Biological Opinion, designed to help restore threatened and endangered species, Coho and Chinook salmon and Steelhead in the Russian River and its tributaries.

This massive document, the result of 10 years of discussion, studies, analysis, modeling and planning, based on existing conditions, sets the stage for a 15 year recovery plan, called the Russian River Instream Flow and Restoration Project (RRIFR), which is expected to cost some $100M to implement. The RRIFR includes operation of Coyote Dam (Lake Mendocino) and Warm Springs Dam (Lake Sonoma) by the U.S. Army Corps of Engineers (Corps) on behalf of the Sonoma County Water Agency (SCWA) and the Mendocino County Russian River Flood Control and Water Conservation Improvement District (Mendocino District).

Funding will likely come from a variety of sources, including ratepayers, state and federal grants, and existing tax revenues that can be designated for this purpose.

The Executive Summary, public meeting schedules, and full Russian River BO report are at: http://www.sonomacountywater.org/projects/

There are many reasons for the decline of these species, including historic overfishing, gravel mining, development near the river and its tributaries, increased sedimentation from logging and historic agricultural practices, and changing climate and ocean conditions. The reasons also include flood control and water supply projects in the river and in Dry Creek. The flood control and water supply projects are the sole focus of the biological opinion.

Essentially, the biological opinion addresses the following questions:
Do the flood control projects operated by the Corps and the water supply and flood control projects operated by SCWA threaten to jeopardize the continued existence of steelhead, coho, and Chinook? If the answer is yes, how can these projects or operations be changed to enable the survival and the recovery of the species?

The BO finds that some aspects of flood control and water supply operations threaten to jeopardize steelhead and Coho, but not Chinook.

1. High summertime flows in the Russian River and Dry Creek

2. The high velocity of water in Dry Creek in the summer

3. The current practice of “breaching” the sandbar at the estuary during the summer

To avoid further problems, some “reasonable and prudent alternatives” (RPA) are proposed, including following:

1. Reducing summertime flows in the river below existing flows mandated by the State Water Resources Control Board’s (SWRCB) D.1610

2. Restoring 6 miles of habitat in Dry Creek

3. Creating a freshwater lagoon in the estuary during the summer months

4. Carefully monitoring both habitat and fish in Dry Creek, the estuary, and the river

5. Eliminating impediments to fish spawning or improving habitat in several streams

6. Enhancing the existing coho broodstock program

At the public meeting held on Oct. 1, NMFS staff said that “success” for the RRIFR Project was not going to be measured over time by actual fish numbers, but by habitat improvements. “Our approach is a habitat one.” - Bill Hearn, NMFS. He also noted that the RRIFR efforts would not address other restoration projects in the watershed, nor would they address erosion, wastewater discharges, runoff, hillside conversions, other water users (legal or illegal) and “other non-project activities”.

The BO will clearly have an impact on future minimum flow requirements and revisions to D1610 by SWRCB, recreational water users in various reaches of the Russian River, and potentially on future water allocations to SCWA contractors.

One of the core questions to be answered remains: if summer and fall flows are reduced in the Russian River, will the remaining water be left in the Eel River? Or will ‘undesirable’ higher inflows from the Eel River merely be used to supplement and increase available water supplies for Russian River water users? Will the Eel River continue to be used to mask the ‘over-appropriations’ of the Russian River?

There will be a series of Community meetings: 11/5 Healdsburg; 11/6 Guerneville; 11/13 Ukiah; 11/19 Jenner. See dates and locations at: http://www.sonomacountywater.org/projects/documents/CommunityMeetingsonBiologicalOpinion_000.pdf

Biological opinion 4.33mg file: http://www.sonomacountywater.org/projects/documents/Signed-RussianRiverFinal_BO_9-24-08.pdf

David Keller

Russian River Flow Changes Ordered

National Marine Fisheries Service says amount of water must be cut in winter to help juvenile salmon

Dry Creek/Russian River Confluence

By BOB NORBERG
THE PRESS DEMOCRAT
Published: 9/30/08

Federal regulators have ordered Sonoma County to reduce the amount of water flowing down the Russian River and Dry Creek and to rebuild Dry Creek habitat to spur the recovery of steelhead and salmon.

The National Marine Fisheries Service also is ordering the Sonoma County Water Agency to find an alternative to breaching the sandbar at the mouth of the Russian River, a procedure that destroys a fresh-water lagoon that forms naturally there.

Steelhead and chinook salmon are listed as threatened and coho as endangered on the Endangered Species List.

“It’s an important document for the recovery of the coho salmon and steelhead,” said Bill Hearn, a National Marine Fisheries biologist. “It looks like the project doesn’t have a significant impact on chinook, but it has huge ramifications to the recovery of coho and steelhead.”

The program could cost up to $100 million over 15 years and would be paid for with local domestic-use water rates and federal funds, said Grant Davis, the Water Agency assistant general manager.

The reduced Russian River flows, however, are being studied by residents of the lower river, whose concern for the fishery is matched by a concern for the impact on recreation.

“We could be looking at a whole lot less water if they are going to reduce the flows,” said Don McEnhill of Russian Riverkeepers. “They are not the people who have to pay refunds to customers who don’t have a good time.”

It is also reviving a citizens group that opposed a low-flow proposal four years ago.

“We will be looking at it and develop a plan to stop the implementation of it, if that is what we want to do,” said Royce Brooks of Guerneville.

The federal Biological Opinion, released under the federal Endangered Species Act, will be discussed Wednesday at a 4 p.m. meeting of the Public Policy Facilitating Committee, made up of representatives of local, state and federal agencies. The session is at the Wells Fargo Center in Santa Rosa.

Water Agency officials said they are required by the federal Endangered Species Act to implement the order, although the actions to implement it are subject to environmental review.

The opinion comes after 11 years of study by biologists and finds that the current way the Water Agency and Army Corps of Engineers run the water system is harmful to the fishery, Hearn said.

The central problem is the velocity of water in the Russian River and Dry Creek. Because of releases from Warm Springs Dam on Dry Creek and Coyote Valley Dam on the Russian River, the flows are too fast for the steelhead and coho juveniles.

The agencies are ordered to reduce the upper Russian River flows by 60 cubic feet per second, to 125 cfs, from July through October. That in turn requires reducing the amount of water released from Coyote Valley Dam and Lake Mendocino.

It would enhance fish habitat, conserve water in Lake Mendocino for the fall salmon run and reduce the amount of water flowing downstream to Jenner, where federal regulators want a natural fresh-water lagoon.

Flows from Warm Springs Dam/Lake Sonoma would be kept at the low end of current releases, about 100 cfs, and restoration work along Dry Creek would be required, primarily with placement of boulders and logs to create pools for fish.

Dry Creek, with the cold water coming from Lake Sonoma, now is a habitat for an estimated 75,000 juvenile steelhead, with a potential for 300,000 with the flows and stream work, Hearn said.

Water Agency biologists, however, conducted a fish survey a week ago and did not find any coho salmon in the creek.

“That is a concern,” said David Manning, the Water Agency’s principal environmental specialist. “Coho are not faring well. That cold water is a tremendous resource. That is a unique condition in this part of California, certainly in the Russian River watershed.”

The reduced flows from both dams would not affect agriculture and would provide enough water for the Water Agency to supply the 600,000 residents it serves from Windsor to San Rafael, said Pam Jeane, the Water Agency’s deputy director of operations.

Still, federal regulators are ordering the Water Agency to study the feasibility of putting a pipeline down Dry Creek Road or West Dry Creek Road to its percolation ponds and pumps at Forestville.

The Water Agency also is ordered to allow creation of a fresh-water lagoon at Jenner by refraining from using heavy equipment to breach the sandbar that forms across the mouth of the Russian River. The agency trenches through the sandbar as many as 10 times a year to keep the water from rising into some riverside homes.

The breach lets salinity into the lagoon, while fresh water would be more beneficial to juvenile steelhead.

Federal regulators want the Water Agency to either let the sandbar breach naturally or build a gradually sloping berm between the river and ocean.

You can reach Staff Writer Bob Norberg at 521-5206 or bob.norberg@

pressdemocrat.com

Article at the Press Democrat

CSPA Files Water Rights Protest to Protect Eel and Russian Rivers

The Russian River Flood Control and Water Conservation Improvement District (“Mendocino District”) has petitioned the State Water Resource Control Board for water from Lake Mendocino under two County of Origin water rights applications. Mendocino claims, based on a reading of old water rights applications and decisions, that water from Lake Mendocino is available for appropriation.

In 1949, the State of California made “State Filings” on behalf of both Mendocino County and Sonoma County water interests in the Russian River drainage. The state filings were made in accordance with County of Origin statutes in the State Water Code, which seek to assure that counties where water originates have water needed for development. Crudely, the idea is to prevent a situation where more developed counties get the water first, leaving none behind for rural and upstream watersheds. In general, California water law requires water users to use a water right, and does not allow water users to save the right to use water for an indefinite period. State filings, recognizing that counties of origin were at a disadvantage both in terms of money and rate of development, are an exception to this general principle.

The problem is that there is no “surplus” water left in the Russian River. Water taken by the Mendocino District will have to be taken away from someone else. Since this is likely to be contentious and involve large amounts of money, CSPA believes that there is a strong chance that some of the water that is being requested will come at the expense of the Russian River, where salmon and steelhead are already doing very poorly.

Complicating the situation is the fact that a large portion of the water that finds its way to Lake Mendocino every year is water from the mainstem Eel River that has been exported through PG&E’s Potter Valley hydroelectric project to the Russian River watershed. This exported water has helped to fuel the rampant growth of viticulture in Mendocino and Sonoma counties, and urban growth in those same counties and also in Marin. While this has continued, the salmon and steelhead fisheries in the mainstem Eel have declined dramatically, and are in danger of extirpation. If more water from Lake Mendocino is promised to Mendocino District customers, it will become harder than ever to restore water to the Eel River watershed.

While CSPA believes that state filings can serve an important function, we filed this protest to protect fisheries and other instream values in both the Eel and the Russian. We also believe that there will soon be many similar requests statewide to appropriate water under state filings. Many, if not most of these future requests will also take place in watersheds that are fully appropriated or over-appropriated. We want to be sure that the State Water Resources Control Board addresses this and future applications for water under state filings in a thorough and protective way, and that the Board employs and establishes a comprehensive process for doing this.

Thus, CSPA has asked for a number of measures and process requirements in considering Mendocino’s petitions. We want the Board to make an up-to-date accounting of water in both the Russian and Eel watersheds, with modern tools. We also want the Board to take a fresh look at all of the impacts of all the diversions in these watersheds, and not accept up front an already unacceptable situation.

Chris Shutes
California Sportfishing Protection Alliance

Appeal for Meeting on Santa Rosa’s Outfall to Steelhead Beach

Hi everyone!!

PLEASE PASS THIS EMAIL AROUND  ANYONE CONCERNED ABOUT THE RUSSIAN RIVER
DIRECT DISCHARGE (SR DISCHARGE COMPLIANCE PROJECT)….Also, please forgive
duplications of this message.

Tomorrow (Thursday) at 5 PM in City Council Chambers the BPU will hold a
meeting to certify the Final EIR on the Discharge Compliance Project, which
includes two direct discharge locations and continued use of the Laguna.
This is not project selection, which will occur in early December.

The length of the BPU meeting will depend on how many people show up.  We
don’t expect a huge crowd but hope to see many of you there.  The BPU had
anticipated certifying the document tomorrow, but we think there is a major
flaw in it.  It is significant that this change in the EIR came as a total
surprise to us.  No one from the City said a word.  The EIR was released on
Sept. 22nd, we could not get it until Sept. 24th, giving us only eight days
to study it.

RRWPC, Friends of Steelhead Beach,  and may others have serious concerns
about this certification action.  We believe there is a flaw in this
document that should prohibit certification at this time.  SR  decided
(without alerting us) to mitigate the damage to Osprey Trail by changing the
route of the pipeline.  That is good for Osprey Trail (most of it anyway)
and shows we (and the Parks Dept.) are having a strong impact on the
process.

The bad part is they did not discuss impacts of laying 48″ pipe in a very
sensitive 1/2 mile on River Rd. (from the park entrance to approximately Rio
Vista, where the pipe will turn into the park and strongly impact the West
end of the park). Remember, they had said they needed a 50′ work area to
install the pipe.  I think that would take the whole road.  There is a
significant drop on the north side of the road, so there really is no
shoulder most of the way.  I have sent a letter (attached) to them
expressing strong concerns and telling them they cannot certify the EIR
without determining  impacts and allowing the public to weigh in on them
(with response).  This could set the process back considerably which they
don’t want to do.

The construction period would last 18 months, a fact that I don’t think was
revealed in the Draft EIR.  It sounds like they would basically shut down
the west end of the park, closing access to very popular Children’s Beach
for at least one summer.  They would close the access at Rio Vista into the
park.  With the construction time up to 18 months, they could go into two
summers.  They would build a coffer dam in order to put the diffuser in the
river.  They would allow boating around it, but it’s likely to be a very
unpleasant experience for people looking to get away from that sort of
thing.

I write a great deal in my letter as to why I don’t think this project is
necessary.  I hope you can take the time to read it.

I hope many of you can come.  This is very important.  They are rushing this
certification process and need to follow CEQA regarding this significant
change in the pipeline route.

BPU MEETING TOMORROW AT 5 PM AT CITY COUNCIL CHAMBERS!!

See you there.

BrendaA

Biological Opinion on Russian River Meeting Oct. 1

FYI:

The notice of pubic policy facilitating committee meeting for the Russian River Section 7 consultation will meet to “discuss, disseminate information and take public comment on the implementation of Section 7 of the federal Endangered Species Act as called for in a Memorandum of Understanding with the US ACE, National Marine Fisheries Service and the SCWA”.

Wednesday, Oct. 1, 2008
4:30 to 6:00 pm
Wells Fargo Center for the Arts, Carston Cabaret
50 Mark West Springs Road
Santa Rosa, CA.

AGENDA

Call to Order

Section 7 Update and Overview

Review of Biological Opinion

Overview of Process, projects
- in stream flow changes
- NEPA/CEQA process
- Dry Creek Interim Projects
- Estuary Adaptive Management

Public Outreach & Information
- Stakeholder Assessment
- SCWA outreach

Future of he Pubic Policy Facilitating Committee

Public Comment

This is going to be very interesting - and telling for our future.  Be sure to spread the word to others you know should be there.

Have a great weekend,
RueBiolocical Opinion

Biological Opinion Briefing Meeting Russian River Watershed

To All,

The National Marine Fisheries Service has been working on a Biological Opinion as part of the Section 7 of the ESA but will focus on the water supply, flood control, and channel maintenance operations within the Russian River watershed.  This potentially is very significant to the type of decisions the Water Agency and the Army Corps can make for future operatio.

The meeting will be held Wednesday, October 1, 2008, from 4:30 to 6:00 pm, at the Carston Cabaret room, Wells Fargo Center for the Arts, 50 Mark West Springs Road, Santa Rosa

–Larry

11th Annual Coho Confab on the Smith River

11th Annual Coho Confab
September 26-28, 2008 on the Smith River

The 11th Annual Coho Confab will be held on the South Fork of the Smith River in the far northwestern corner of California. This dynamic event is sponsored by Salmonid Restoration Federation, Trees Foundation, Smith River Alliance, Smith River Advisory Council, and Cal Trout. Orientation presentations will focus on fire ecology and fisheries, coho salmon recovery, and the significance of the Mill Creek watershed acquisition in protecting and restoring a salmon stronghold. This year’s Confab will feature restoration tours in the Mill Creek watershed, tributaries of the South Fork, Yontucket Slough and the Smith River estuary. Randy Lew of Pacific Watershed Associates will lead a tour of road decommissioning and erosion control projects in Dominie and Rowdy Creeks. State Park geologist Rocco Fiori will discuss experimental wood loading designs to enhance stream function and salmonid habitats. A full-day tour of Mill Creek restoration projects will include presentations by Dan Burgess of Rural Human Services who will lead a tour of the native plant nursery for Mill Creek restoration, Lathrope Leonard of Redwood National and State Parks will lead a forestry tour focused on restoring late seral forests and Brian Merrill of California State Parks will discuss backcountry road management in North Coast Redwoods State Parks and rehabilitating watershed function.
Rod McLeod of the Mill Creek Monitoring Program will lead a hands-on workshop assessing juvenile coho summer abundance estimation in Mill Creek. Zack Larson, watershed coordinator of the Smith River Advisory Council, will facilitate a Smith River fish identification workshop.
Antonio Llanos of Mike Love and Associates will lead a tour of fish passage projects and will co-lead a tour of Yontocket Slough and the Smith River estuary with Zack Larson, Watershed Coordinator for the Smith River Advisory Council. Other workshops include instream fish identification, and macro-invertebrate sampling and stream health assessment. There will be an open forum entitled “Stories and Songs of Salmon” with native stories from Frank Lake and river troubadour Alice di Micele. and there will be an open forum and resource workshops. Saturday night will culminate with a wild salmon feast, and a cabaret.

Advanced registration fees are $100 that includes all camping, food and lodging. After September 5, registration is $125. For more information about the Confab, please visit www.calsalmon.org or www.treesfoundation.org . To register online and obtain logistical info please go to http://treesfoundation.org/cgi-priv/Conference.pl . To see the agenda or download a registration form to fax or mail, go to http://www.treesfoundation.org/cohoconfab/ConfabReg2008.pdf

SRF Central Coast Bioengineering Field School October 20-23, 2008 in the Santa Ynez Valley

SRF, with the support of the Department of Fish and Game, will sponsor a Bioengineering Field School on the Central Coast. Instructor Evan Engber, of Bioengineering Associates, will teach techniques to restore riparian habitat, control erosion and stabilize banks. Participants will tour projects in San Luis Obispo and Santa Barbara counties and learn how to build willow matresses and live siltation baffles. Due to state budget freezes for agency travel, SRF has selected a more affordable location to host the field school. The dates are now October 20-23 at Camp Whittier . These are lodge accommodations with four to a room. The fees for the course are $300 which includes all instruction, materials, food and lodging. For more information, please see the registration form at www.calsalmon.org . Additional lodging can be found in the closest town of Solvang. The Solvang Gardens boutique hotel will honor the government rate for participants. Please see their web site: www.solvanggardens.com/reservations.html

Francine Allen
Project Coordinator
Salmonid Restoration Federation
PO Box 784
Redway, California 95560
(707) 923-7501
francine@calsalmon.org

Garcia and Gualala River Condition

Attached is an update on current conditions on the Gualala and Garcia rivers.  Currently the very low levels of flow are challenging fishery survival. This is true on many of our north coast rivers..

There are minimum by-pass flow conditions (established by DFG)  in place on the Garcia and Gualala rivers that are not being enforced.

Garcia River

While the current low flow conditions are dire outstanding complaints on diversion by Walter Stornetta Dairy - where there are illegal water transfers going on and pumping beyond license conditions. This complaint has been before the Division of Water Rights for over 4 years. Last Sunday when I drove by the Dairy  on a very warm and extremely windy day there was massive irrigation ongoing on no less than 5 very large fields (far in excess of 20 acres per field).   This instantaneous draw down must of been quite large. The evaporative effects and water loss of the irrigation probably was in the range of 20% to 30% due to the wind.

Gualala River

Flows on the Gualala River are extremely low. Lower than any of the locals have ever noted - with major sections of the stream disconnected.  There is currently minimum by pass flow conditions set on the North Fork (North Gualala Water Company), and in the mainstem.  These by-pass flow conditions are not being enforced.  In fact, the North Gualala Water Company does not have water conservation plans or a program in place - as called for by their license.

If fish are to survive, they need water.  I ask you to enforce current conditions and to promptly move forward on your north coast rivers flows policy.  This situation is urgent.

Alan Levine