Russian River Low Flows Letter

Dear Ms. Whitney:

I submitted extensive comments on the Emergency Order issued by your office
in April regarding water diversions from Lake Mendocino in Sonoma County.  I
also attended the Board Workshop in early May and gave testimony on this
issue.  I represent Russian River Watershed Protection Committee, a local
non profit that has been in existence since 1980.  We have about 1400
supporters who are mostly property owners along the lower Russian River.

I have had a few conversations with Eric Oppenheimer of your staff about my
concerns about the revisions of the Order. He was very nice and tried to
answer my questions, but told me he did not have time to “dig up documents”
for me to respond to my specific information requests.  I have been trying
to find out how the 37,500 AFY diversion limit from Lake Mendocino is
determined; what the 25% “cut” is based on and how calculated using 2004
data, and how the 25% cut in deliveries to contractors will be determined.
I wanted to know the exact amount diverted from LM in 2004 under SCWA’s
water right permit and couldn’t find out.   I wanted more information on the
“turf watering situation” also and was told that was being revised.

I have requested information about diversion history and methods (reports)
from both your Agency and SCWA (2002-2008).  So far I have not been allowed
to review any documents on this subject. (I am unable to come to Sacramento
to review documents.)   I was looking for reports by SCWA to your Agency on
Lake Mendocino diversions.  There is a community meeting on this issue on
May 28th  and I have been asked to take part.  I requested this information
from SCWA a week ago, and I was told I had to wait ten working days (2+
weeks) and would not have information in time for the meeting.  I have also
been playing phone tag with certain SCWA staff on this and they somehow have
not been able to call me back at the wide range of times I was available.

When your Emergency Order was first released, the situation with Lake
Mendocino (LM) appeared much more dire than it is today.  The gap between
this years water supply pool and last years was worthy of great alarm and
perhaps deserving of the “critical dry” designation being proposed for July
6th to Oct. 2nd (?).  But the comparison curves between this year and last
have now come much more closely together after five days of heavy rain
earlier this month.  Lake Mendocino has stayed around and over 56,000 AF for
quite some time now, while the curve for 2008 is rapidly going down.  At
this point, there is only about 12,000 or 13,000 AF separating the two
curves.  We do not feel this merits the “critical dry” designation and we
ask you to determine that a “dry year” designation is adequate for this

It is our view that the “critical dry” designation would cause massive water
quality problems in the lower river, not to mention a major impact on
tourism and recreation in our area and should not be used unless the water
shortage is truly dire and comparable limits are placed on other water

The people of the lower river community are wiling to live with the “dry
year” designation, but do not feel that circumstances merit pushing flows to
“critical dry” under the circumstances.  We are not sure that enough is
being done by SCWA contractors.  While Santa Rosa has accomplished a lot
with their conservation efforts, we feel that if the situation is dire
enough for a “critical dry” designation, then the cities should have
mandatory conservation requirements and not just “Stage 1”, voluntary
conservation efforts.  It’s simply not fair that we get as much as a 70%
cut, and they get about 10%.  (If the 25% is based on 2004 diversions,
according to my understanding, they get credit for all they have done
between 2004 and 2008, which is about a 15% decrease in water use.)

I sincerely hope that you will apply a “dry year” designation only in your
revised Order.


Brenda Adelman
Russian River Watershed Protection Committee
P.O. Box 501
Guerneville, CA 95446
(707) 869-0410 (phone and fax)

PS:  Attached article appeared on the front page of the West County Gazette
in their May issue