CSPA files comments for flows on Coastal Streams
by Chis Shutes, FERC Projects Director
Friday, March 26, 2010 -- CSPA filed comments today on the Final Draft Policy for Maintaining Instream Flows in Northern California Coastal Streams. This policy under consideration by the State Water Resources Control Board affects the counties of Napa, Sonoma, Mendocino, Marin, and part of Humboldt, with the exception that it does not include rules for the mainstem Russian River.
The new draft policy represents some improvements when compared to earlier drafts, notably in shortening the season of diversion. However, it fails to require the monitoring and reporting of diversions and of streamflows that are needed to understand both the current level of stream impairment and the overall effect that new diversions might have on fisheries in the policy area. It is still too vague on enforcement, and it provides no process for evaluating its effectiveness.
Perhaps most importantly, the criteria for evaluating cumulative effects of existing and new diversions are not clear. Parties that do not meet what requirements there are will be allowed to make the case that new diversions should be allowed if the new diversions does not make a bad situation measurably worse.
Read the comments here.