Members of the Public Policy Facilitating Committee:

Thank you for the opportunity to comment today on the Draft Biological Assessment, specifically that section that proposes a new summer flow regime for the lower Russian River.

Last week the public got its first viewing of the proposal at the Low Flow Forum in Guerneville. I want to thank Supervisor Mike Reilly, who facilitated the event, for ensuring that despite the crowd’s obvious skepticism of the plan, civility was maintained. There was opportunity for proponents to describe the plan and explain its rationale and for the audience to ask important questions. While ENTRIX consultants and Sonoma County Water Agency staff did a good job at describing the Low Flow proposal and why they thought it might be beneficial to the recovery of the river’s salmon and steelhead population, as the evening went on, it became clear that the Low Flow Proposal was deficient.

Members of the panel and the audience brought up a number of issues that needed more study, but huge gaps in the underpinnings of the Low Flow proposal were most readily apparent:

The authors of the Draft Biological Assessment apparently did not understand that any change in flows in the Russian River must be accompanied by protection if not improvement of water quality, and that temperature is but one element of water quality. Fish cannot live in degraded water; humans cannot drink it or swim in it. Yet ENTRIX only looked at how changes in temperature could have a beneficial effect on salmon and steelhead, providing only a cursory examination of how other elements of water quality might be affected by significantly reducing summer flows. The proposal did not look at what would be the effects of spills, septic seepage, and pesticide runoff as well as nutrients from the Laguna de Santa Rosa when they are less diluted in a low flowing river.

I am, in fact, shocked and amazed that water quality was deemed such a peripheral aspect of this proposal, so that in the interest of moving forward, there was almost no discussion of these issues in the Draft Biological Assessment and data gaps were not even identified. Instead, at the Guerneville meeting, an anxious public was left with vague promises that these concerns would be looked into in the future. When issues so basic to the survival of the fish species and the well being of human communities are left out, the credibility of the entire Draft Biological Assessment is called into question.

It is true that this proposal has a long way to go and many regulatory hurdles to overcome before it is implemented. Yet the flaws in the proposal are so great and so glaring, that it would be folly to try to move this incomplete plan forward in April as currently scheduled. Once this proposal is officially put on the table, and its sponsors become invested in it, it will be difficult to change course. Taxpayers and ratepayers would be prematurely committed to hundreds of thousands, if not millions of dollars of consultants’ fees and expensive studies, and very likely, litigation.

The Low Flow Proposal will receive its first test of scientific validity when the Independent Review Panel reports back to you. I ask that you listen intently to that committee, and that the Draft Biological Assessment not be submitted for agency review until the Independent Review Panel’s concerns, and the legitimate concerns of the public, are fully dealt with. If further studies need to be done, do them before the Biological Assessment is finalized. If it is too expensive to do these studies, then we need to know now rather than later. If the studies demonstrate that the Low Flow Proposal should not be implemented unless other issues are addressed first, then the proposal should be withdrawn and other alternatives more fully examined.

You who sit on the Public Policy Facilitating Committee are among the few that share the responsibility for managing the Russian River. Please know that I support your efforts to change management practices so we can restore the Russian River’s once great fishery. I am confident that with our best efforts and the best science we can succeed.