Hi all, This is just a friendly reminder that comments to SWRCB for the frost protection workshop are due NEXT Tuesday, 11/10 at NOON. See below. You have probably all seen this Ukiah Daily Journal article about a recent Farm Bureau and FFF meeting and the 11/18 SWRCB workshop. As the FB noted in the article, "Whoever is in that auditorium is going to make the difference." I agree, and I hope lots of people can attend. http://www.ukiahdailyjournal.com/ci_13718542 Also attached is the NOAA letter referenced in the article. Following are a few issues that I believe will be discussed. The most consequential threshold question is the first. * Will be a SWRCB reasonable use regulation, as NMFS has stated there should be, or whether it will continue to be an informal and 'opt-in' program? I don't believe there is any way to get broad action within the industry without a rulemaking. Although a few farmers have made large investments to make things better on their property (and I believe they should get credit for acting), there will always be many who will not participate without regulation. Similarly, it's not fair to those who do act to let others be free riders. * Will there be an emergency rulemaking for this year, as well as a permanent rulemaking for the future? * Will the rulemaking require compliance with other laws? (Water rights, streambed alteration agreements, etc.) * Will it require automatic recording and reporting of the timing and quantity of diversions? * Will it require monitoring of stream conditions? * Will there be a focus on tributaries? * Under what conditions, if any, will diversions for frost protection be allowed? (I.e., will it be a flat prohibition, or a requirement that diverters prove no harm to fish before diversions, or will the state be required to show harm to fish for diversions to be curtailed, etc. Will it follow the Napa model and allow diversions only if there are regulating ponds and a rotation system for refills?) I'd be happy to discuss comments with any of you in advance. Just let me know. Brian - Brian J. Johnson The State Water Resources Control Board has issued a notice of public workshop to consider recommendations for actions to address the effects of water diversion practices for frost protection of crops on salmonids in the Russian River watershed in Mendocino and Sonoma Counties. The public workshop will commence on Wednesday, November 18, 2009 at 1 p.m. in the Coastal Hearing Room at the Cal-EPA Building in Sacramento, California. Comment deadline is November 10, 2009 by 12 noon. Please find attached the notice of public workshop. The notice will also be available shortly at the Division of Water Rights' website at http://www.waterboards.ca.gov/waterrights/water_issues/programs/hearings /russian_river_frost/. If you have any questions regarding this notice, please contact Jean McCue, at (916) 341-5351 or email@example.com, or Dana Heinrich, at (916) 341-5188 or firstname.lastname@example.org.