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Riverkeeper View of Fish-Flow & Water Rights Project - Part 2

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Riverkeeper View of Fish-Flow & Water Rights Project - PART 2

By Don McInhill, Russian Riverkeeper

PART 1: A Watershed View of Problems and Opportunities for the Russian River

Last month I wrote about how the Russian River has lost 75% of its former area and how that has eliminated thousands of acres of upstream flood storage. We saw this fact play out in the January flooding in the lower Russian River and Santa Rosa plain. During post-flood cleanups over several weeks we witnessed the reality of having no off-ramps for pollutants like sediment. Instead of ending up in wetlands or floodplains upstream, it ended up covering everything in the lower river that was under water with a slimy fine mud, when the floodwater dropped. The good news is all that water will help in improving conditions for recreation and our endangered salmon this coming summer

We contrasted two reports on the River, the Russian River Independent Science Review Panel Report (IRSP Report) and the Fish Flows and Water Rights Project EIR (Flow EIR). Last month we discussed the watershed view of the ISRP Report, this month we’ll dive into the Flow EIR.

Why Lower the River Flow?

The Flow EIR is primarily in response to the changes sought by the Russian River Biological Opinion (RRBO) from 2008. Biological Opinions are required when endangered species are present due to Section 7 of the Federal Endangered Species Act. Section 7 requires a review of any Federal (US Gov’t in other words) operations that might negatively impact any endangered species. In our RR those are Coho Salmon, Steelhead Trout and Chinook Salmon. The Federal operations include management of Lake Mendocino and Lake Sonoma by the Army Corps and Sonoma County Water Agency (SCWA) via their water supply releases, diversions and flood control operations of the SCWA. The RRBO concluded that the current summer flows and estuary management posed a threat to the Salmon and dictated that seventeen actions be taken to mitigate or offset those threats. 

The RRBO mandated action to seek a permanent 44% reduction in summer flows. This is the main driver for the Flow EIR and has raised a flood of controversy due to likely impacts to recreation and water quality in the summer months. The RRBO concluded that lower water velocities in summer would improve habitat for juvenile steelhead in the upper Russian River. It also stated that current summer flows disrupt the formation of a “closed lagoon” in the Russian River estuary reducing habitat quality for salmon. 

Since SCWA operates the dam releases in summer and manages flood control breaching at the river mouth, they are responsible for seeking the RRBO required changes, hence the Flow EIR.

Public comments on the Flow EIR HAVE BEEN EXTENDED TO MARCH 10TH.

At the same time in order to change summer flows, SCWA has filed a Water Rights petition to the State Waterboard and the public has a right to file Protests to that Petition. 

State Water Resources Control Board has extended the protest deadline to 4:30pm on March 10, 2017.  To view the re-notice project information, please visit the Division of Water Rights website at:

Both have a lot of people writing comments and protests in response to their concerns about the impacts of reduced summer flows.

The Flow EIR Project has five parts with two relating to updating water rights permits, one on revising the “hydrologic index” for the river and two focused on reducing minimum required flows.

Two Parts to the Puzzle 

We’ll focus now on the two flow reduction parts since they are controversial. 

According to the Flow EIR, reducing summer flows can create benefits for salmon by keeping more water in small Lake Mendocino, which helps preserve cold water deep in the Lake. Flow reductions would improve summer rearing habitat for juvenile steelhead trout in the Ukiah to Cloverdale reach, according to the Flow EIR’s Upper Russian River Habitat Model. The EIR also states that flow reductions would reduce inflows into the estuary and reduce the need to mechanically breach the sandbar, thus preserving stable rearing habitat in the estuary. 

At the same time, the Flow EIR states that flow reductions would also result in “significant and unavoidable” negative impacts to water quality, potentially harming both salmon and recreation. 

The Flow EIR Project seems to set up a clash between the Federal Endangered Species Act and the Clean Water Acts – how can this be if it’s good for the River? 

Upper Russian River at Ukiah Valley

Alternative Solutions

At Russian Riverkeeper we’ve been studying the whole notion of reducing flows since 2003 and think there are superior alternatives we must consider to help our salmon, ensure a more reliable water supply and preserve our right to a clean, safe river. Our biggest concern, shared by many, is that reduced flows will lead to increases in nutrient concentrations that are not healthy for salmon and are a factor in toxic algae blooms. We have other concerns such as reducing the production of salmon prey and negative effects on recreation from water quality and conditions too shallow for kayaking and canoeing. 

Let’s think about how we could reduce these impacts and still achieve the project goals.

One of the goals of the RRBO and Flow EIR is to preserve cold water in Lake Mendocino for fall migration, a good idea.  Of course, we’ve been told summer flow reductions over the last 8 years are intended to preserve that cold water – but it's never been used to benefit salmon. We must use the water rights petition process to assign a “block” or water or water right to 15,000-20,000 acre feet of water in the lake. We should assign rights to this block of water for salmon ahead of other rights to guarantee it’s there when they need it, like many other CA salmon streams. 

Toxic Blue-Green Algae

Looking at alternatives to reducing flows to preserve more cold water in Lake Mendocino, we look to the Sacramento River and Delta. The Delta watersheds like the Russian River, has thousands of water diversions for various needs that compete with preserving water quality for endangered fish. In the delta the State Division of Water Rights places affirmative restrictions on some classes of water rights to ensure water is available for fish. 

On the Russian River during summer most water in the upper Russian comes from Lake Mendocino, which is stored during the rain season and re-released later in the year. Riparian rights to water in the Russian are limited to natural flow. 

In the Delta when natural flow runs out, riparian diversions are prohibited to ensure water released from dams for fish isn’t taken inappropriately. This legal limit on water diversions would result in more water saved in Lake Mendocino and could offset the need for reducing summer flows up to 44%. This could keep cold water in the Lake for fish and reduce impacts from reduced flows.

Let’s take a different look at the estuary issue. 

The Flow EIR states high flows increase the need to breach the sandbar at the river mouth, which degrades habitat for salmon. We have a different view that it’s the less than two dozen structures like Sonoma State Beach Visitor’s Center (shack on stilts), Jenner Post Office (shipping container like structure), decks and non-residential structures at risk of flooding that causes the need to breach the sandbar and degrade habitat. 

According to widely accepted Sea Level Rise predictions, these structures will be underwater at high tide due to climate change in roughly a decade – why not spend a few million and elevate these structures? There are state funds that can help offset the cost to homeowners and the County. If we elevated these few structures as we have upstream, then the estuary could rise higher and create even more habitat in places like lower Willow Creek. This alternative eliminates the major driver for reducing flows and achieves the goal of improving estuary habitat.

Jenner Visotors Center at Jenner Estuary

If approved as is, the Fish Flow Project would result in drought-like conditions for recreation and endangered salmon – no matter how much rain we get. There are feasible alternatives to the proposed 44% flow reduction as the only solution to improving salmon habitat that would accomplish project objectives. 

We believe the proposed “fish flows” are just too low for either salmon or humans. 

Let’s all work towards realistic Flow EIR alternatives and mitigations to ensure that we improve habitat for salmon and preserve water quality so our residents and visitors can have a safe, healthy summer.




Russian Riverkeeper is a Healdsburg-based not for profit community benefit organization that depends on your tax-deductible contributions for our work.  To donate or learn more about our work, please visit!





Brenda Adelman of the Russian River Watershed Protection Committee reminds us that the Water Agency is in charge of the Environmental Impact Report (EIR) and they collect the comments.

The CA Water Board is in charge of water rights and will be making the decisions on low flow.  They receive the protest letters which are due at the same time as the EIR comment letters.  The Water Agency must receive copies of the protest letters.  We have assured that they received all that were given to us.

RRWPC prefers that you send any letters to us so we can forward on to the appropriate parties.  Thanks for your help with this.  We also encourage to make copies of either/both letters and send them to RRWPC at P.O. Box 501, Guerneville 95446.  We will also be sending out a mailer mid-month that will contain a hard copy of the EIR comment letter to the Water Agency.