I’m writing to second David Keller’s request that we write and attend the upcoming SWRCB meetings this month. My focus here is on the meeting on June 19th – the workshop to receive policy direction on Water Right Enforcement. The Notice on this meeting states the their are currently 500 pending water rights applications, many for existing unpermitted uses.
The company that I work for has recently been contracted to assist a Hydrologist conducting Water Availability Analysis for several Water Appropriation Applications ( both acronyms WAA – just to keep things confusing) for tributaries connecting to the Russian River.
This may be old information for some of you – but I just recently learned about this: Apparently SWRCB occasionally does fly-overs and notes any visible reservoirs that the State does not show permits for, then contacts the property owner to “request” they file an application to appropriate. Interestingly enough, because these water bodies are existing reservoirs, the State is encouraging a Categorical exemption from CEQA analysis (Section 15301) and seems to be seeking only to find out how much water is being taken, and stored – The point being than ANY surface flows are part of the watershed that is being diverted from a stream somewhere. Therefore any reservoir must be permitted and show the water taken is not adversely affecting downstream flows, thus public trust doctrine comes into play and this is where folks like Trout Unlimited come in and protest water applications.
If you are not already on the mailing list – you can sign up to recieve notification of the applications here:
It is always interesting to see who in the neighborhood is applying for the already over-appropriated Russian River water!
The reservoirs that I happen to be looking at currently are small, and are probably not effecting streamflow to the Russian River directly, but when you have large vineyards diverting water, or any large agricultural use for that matter, it SHOULD be questioned how much water is being taken. I know – I am preaching to the choir here – Technically any reservoir could act as a means of replenishing the local aquifer. Whether ag is using reservoirs or groundwater – there is a TON of it being sucked up – no coincidence that So. Co is also looking at using reclaimed water instead – there is just not enough to go around for ag and residential and still leave enough for the fish.
I’m glad that SWRCB is actually attempting to monitor and assess how much water is being diverted, but this is just the first stage of a long process, because as we all know, governments may be very good at making rules, but without any enforcement process behind those rules, no change will occur. My concern is that without CEQA being a part of the process, which requires mitigation to occur and a monitoring plan (thereby SOME kind of enforcement), I feel the agency is remiss in not looking at the whole picture. This whole thing is so new, there are only 3 CEQA docs posted on the Water Rights site, Initial Studies with Mitigated Neg Decs.
I’ve been working on writing a letter from the perspective of an environmental planner, but I am still new to this and could use help from those of you who may have already been doing this for a while.
Comments for this meeting are due 6/6 by noon. PLEASE HELP!