The Biological Opinion was based on NMFS views (ratified by Cal Fish & Wildlife) of how to substitute fish-rearing habitat to compensate for all the human-imposed changes to the Russian River, (apparently, in my view) without having to face off with any landowners in the tributaries OR along the main stem (except for the very few places in Jenner that might get swamped). The agencies focused on the SCWA operations that could be detrimental for salmonids, because that is the only target with the funding and the authority to support a system project involving more than one segment of the system.
At the Introductory workshop in Monte Rio, Bob Coey told me that it’s mostly aimed at steelhead, because they rear throughout the system, and are not as dependent on tribs as the Coho. Of course, the DEIR states that it’s about ALL the salmonids, but nobody ever accused this project of having a consistent focus.
So why the timing on creating the ISRP?
We don’t know exactly whose idea it was. If it was Grant’s (or Jay’s) I have to wonder if the aim was to create a framework for testing the effects of lowering flows. (They did not expect that ISRP would take this long.)
SCWA has already been lowering flows according to the Biological Opinion’s prescriptions, getting separate permission to do so under 1610 each year, as they described at the hearing.
So now is the time to implement a study of the initial effects, which could be based on the science that have been collected and reported piecemeal for several years.
SCWA took steps to improve the scientific studies, and programs for reporting them, after about 2010 or 2011, when the agency held the first major gathering of the various entities and Counties involved. Efren was very newly in his Supes position, and I affronted him at that first program by reaming out SCWA staff for claiming that “the statistics” showed no changes in water quality.
I had read the initial reports that detailed all the water quality data they had gathered in prior years, which were so few and scattered that neither seasonal nor annual variations could be analyzed for any of the collection sites. I demanded that SCWA explain what statistical tests they had found to use, since they had so few and inconsistent data, and of course they could not. I followed up with email and calls, and eventually they had to admit that they had no statistics.
Everything got put onto a more scientific basis after that, via funding for the RCDs. They started doing more consistent water quality sampling and studies of food chain species, etc. Those data may be worth looking at to determine if they can form the basis for a preliminary evaluation.
Given this issues raised. There are policy implications that may (or should ) be applied to Russian River proposed low flow management (and the Biologic Opinion)
First: The Biologic Opinion and proposed low flow scenario were not privy to the findings of the ISRP. They findings should be amended into the Biologic Opinion and any proposed management policy consideration (for consideration of conditions and related effects of proposed management policy). The ISPR provides a the latest and best information as to current and historic conditions – and – must be considered as same in any environment review of proposed management policy.
Next: If habitat conditions in the tribs are, in fact, as described in the IRSP ( essentially devoid of historic habitat necessary to support salmonids in all life stages – see below) – then, in fact, that it may be the case that the mainstem Russian River (and higher than historic natural flows) may be a necessary habitat component to maintain – until such time as the tribs have be rehabilitiated.. That is: Essential flows, shading and near stream habitat, and instream habatat conditions in the trims need to show improvement before any low flow policy should be implemented.
This would require limitation of near stream and instream water diversion in the tribs (especially during the non-rain seasons) and development of near stream canopy for shade and temperature control conditions – and – possibly some restoration work to provide instream habitat conditions (to encourage deeper pools, overwintering habitat, and other refugia, and remval of fish migration blocking obsticles). This work would have to be accomplished and show demonstrable success – prior to the implementation of any low flow policy.
All of these issues must be addressed in the informed decision making process – attendant to CEQA, NEPA, and federal responsible agency mandatory consultation.
Discussion and argument to be made:
As the IRSP noted the historic Russian River flows were lower.
However, during that by-gone history things were different – in how the system
Prior to current hydromodification – there was more refugia for fish – both – in the tribs and in the mainstem.
Both – tribs and mainstem – had deeper holes and cooler water.
There was more shading on the mainstem and tribs to help keep things cooler in the refugia areas.
The tribs had more water (not being pumped dry for Ag irrigation – plus – the rain cycle has changed)- thus providing cooler water and deeper pools for refugia and fish survival in all life stages.
And – finally – the near stream environment had more gravel terraces storing more water and cooler subsurface flows (plus deeper and cooler pools).
All these conditions aiding the life cycle needs of salmonids have been altered (mostly gone).
What do you think ??