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Re: Russian River Biological Opinion and RR Low Flow DEIR

All—

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.

Jane