HomeMy WebLinkAboutStaff Report ® 03723/2001 05: 13 707-565-2624 so CO COUNT' • COUNSEL = GE '-a?/13
COUNTY ADMINISTRATION CENTER DEPUTIES •
575 ADMINISTRATION DRIVE, • j �,_a,
A ROOM 105A 6 F1/ KA ,M Y Lax
SANTA RoSA, CALIFORNIA 95403 Jw.D.Go us %ta s R RCss
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\ K+n,irs4 M.lwoeua Pmus GAUAGZIER
• FUR SUZANNE M.DefoLw Gnnacer t CIe..
SUE OAUAUriEE Stever S.SNUPE
CHIEF DEPUTIES OFFICE OF THE COUNTY COUNSEL TA"Kars "' Yaw A. er
Nei C RAYS -
STEVEN M.WOODSIDE
H.
ROsewaY H.MoR
pp/ Ccuaty Counsel
Date: 3 tea
To: I iretta / V Etg
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Fax No.: 9/6/14 — 7799
From: Steven M. Woodside .
Tam Harvey
Neil C. Baker • _ Sheryl L. Bratton
Rosemary R Morgan Jeffrey L. Bern
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Kathleen M. Fazrelly Sally B. McGou.gh
—Trill D. Golis Bruce D. Goldstein
. Byron K_ Toma David R McFadden•
C. David Hurst Phyllis Gallagher •
itichaid M. Flores Gregory Dion
Kathleen Larocque • Steve Shupe "r
Snnnnr M. de Kazan Mitchell -
chell
Sue Gallagher Anne L. Keck
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33446
03/28/2001 09: 13 707-565-2624 S0 CO COUNTY CC!_+E__ PAGE 02/13
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Law Offices of
STEPHAN C. VQLKER •
43634" Street,Swte•1300 • •
diaceand,%Callfornia'94612 >IIe No.17.118
TEL 5i0/496-3600<"FAX:;Sto/loo-1366
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March'26:2001
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VIA•FAX(70'I)565-3778) —ORIGINAL BY:'fi.4IL DICTATED BUT:NarREAD
Honorable fund Smith .
Chair..Eoard of-Directors
Sorioma,County'Water Agency • , ..
575 Administration Drive. Suite 100D. •
Santa Rose,-CA 95403-2815
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Re: Eleventh Amended Agreementfor Water Supply and Ratification of Execution of
: Agreement (Agenda Itetn No. 4;:March 27, 2001)
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Dear ChairnanSmith: • •
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• On behalfof•Friends of the Eell.River ann.associated conservation groups+and concerned
citizens;I write to advise your Board of Directors;of our opposition'to your proposed approval and/or
ratification of the above-referenced Eleventh Amendment to the Water Agency's water supply
agrrecthentl Our opposition to this proposed anencmentis based on the numerous violations of state
and federal'law described in our enclosed PROTEST OF FRIENDS OF THE EEL_RIVER,
FRIENDS OFTHE RUSSIAN RIVER, PACIFIC COAST FEDERATION Or" FISHERIvfN'S
ASSOCIATIONS ,CALIFORNIA SPORTFIST3LNO PROTECTION ALLIANCE,WIYOT .
TRIBE OF THE.TABLE BLUFF RESERVATION, COYOTE(FRED DOWNEY,Ph D:),.L.
MARTIN GRIFFIN,M.D and FRANK.EGGER,•filed with the State Water Resources Control
_ Soard':on Septerber 1•,2000, In.addition, we incorporate herein by reference he additional
nolat[ons of<the'Bcown'Aci docvarente,.d•m the letter submitted In attorney Andrew Packard on
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February 22,2001 which is referenced in your proposed Resolution for approval of,he Eleventh
Amendment, We are,further dinccned that neither the Watt Agency, nor any of its water supply
contractors, has conducted a proper review of the Eleventh Amendment under the California
1 Environmental Cuslity Act.
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Thank you for considering our objections regarding this importent.maiter.
Respectfully submitted,
/ K0 -
steDnzi C:\-olker
Attorney for Friends of the Eel River, Friends of the Russian River,
Pacific Coast Federation of Fishermen's Associations California
• Sportfishing Protection Alliance,Wiyot Tribe of the Table Bluff
Reservation,Coyote(Fred Doty, Ph,D.),L. Martin Griffin,
M.D. and Frank Egger _
SCV/jb •
Enclosure •
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707-565-2524 SO CO COUNTY COUNSEL ww 6e Lz
03/23/2001 09: 13 y
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1 STEPHAN C, VOLKER, (CSB y63093) •
BP.E.CHER &VOLKER`LLP c,,•
436 14i° Street, Suite 1300 av oc ::
Oakland, California 94612
3 cue c..
TEL• 510/496-0600 s� v
4 ?"-AX: 510/496 1364 `a'� -. ,:'�
5 zy�` � i
Attorney for Protestants rriends of[he Eet River .,
6 Friends of the Russian River, Pacific Coast Federation o
California Sport-ffishing ''s
of Fishermen's Associations, N
7 Protection Alliance, Wiyot Tribe of the Table Bluff
S Reservation, Coyote (Fred Downey, Ph.D.), L. Marts
Griffin. M.D. and Frank Egger
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9 .
10 BEFORE THE STATE WATER RESOURCES CONTROL BOARD
OF THE STATE OF CALIFORNIA ,
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12 In Re Water Appropriation Application Nos. ) PROTEST OF FRIENDS OF THE EEL
13 12919A, 15736, 15737, 19351 and 30931: ) R, FRIENDS OF THE RUSSIAN
14 Notices of Application to Appropriate Water ) RIVER, PACIFIC•AS O COAST
TTt.O FEDERATION OP
from the Russian River and Petitions ) CALIFORNIA SASSOCIATION
15 I Requesting Changes. or Extensions of Time, ) WIYOT TRIBE
16 in Water Right Permit 12947A, 12949, 12950 ) PROTECTION ALLIANCE, WIYO RIB
Wd 16596 from for Diversions iv or Re-Diversions the Sono a ) COYOTE (FRED ED DW EY Ph,D.), L.
17 ,Water frost the Russian River by the Sonoma ) MARTIN GRIFFIN, M.D. and FRANK
•County Water Agency ) EGGER
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19 ) NOTICE GROUPS I and II
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TO THE ABOVE-ENTITLED AGENCY AND TO THE APPLICANT SONOMA COUNTY
23 WATER AGENCY: •
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24 PLEASE TAKE NOTICE that Friends of the Eel River,Friends of the Russian River, Pacifi
of
25 Coast Federation of Fishermen's Associations, California Sportfishmg Protection Alliance, y
26 Tribe of the Table Bluff Reservation. Coyote(Fred Downey, Ph.D.), L. Martin Griffin,M.D. and
27 Fri; Egger hereby protest, pursuant to Water Code sections 1330, 1331 and 1704 and Title 23,
28 sections 745 and 796 of the California Code of Regulations. Water Appropriation ApP11 tion No.
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03/26/200 • 09: 13 707-565-2624 SO CO COUNTY COUNSEL .. PAGE 22/1_
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1 30981, and petitions to arnend Water Appropriation Permit Nos. 947A, 12949, 12950 and 16596
2 (Water Right.Application Nos, 12919A, 15736, 15737 and 19351), filed by the Sonoma County
3 I Water Agency ("SCWA") (hereinafter, the "SCWA Applications").The names of the protestants are
4 l set forth on page 1 of this Protest. Protestants may be contacted through their undersigned attorney,
5 whose address/appears on page 1 as well. Protestants and their interests in this matter are described
6 below. Protestants have reviewed this.Board's notices of the SCWA Applications, and would agree
• 7 ( to dismissal of this Protest only if the following Grounds for this Protest are resolved.
8 [ . GROUNDS FOR PROTEST •
9 This Board's approval of the SCWA Applications would not best conserve the public interest
10 and public trust uses,would have adverse environmental impacts, and would be contrary to the Public
11 Trust Doctrine and other,laws in the fallowing respects:
12 1. The SCWA Applications would deprive the affected watersheds and their citizens of
- 1.3 water needed to protect beneficial uses and the public interest, contrary to Water Code sections 1243-
14 45 and 1253_ SCWA is cisting and proposed appropriations adversely impact the fish and wildlife •
15 of the Eel and k ssian River watersheds, and harm the recreational and economic interests of citizens
• . 16 of Humboldt, .Mendocino, Sonoma and Math Counties. The SCWA Applications depend on
17 continued diversions of water from the Eel River m the Russian River.These diversions average over
18 160,000 acre feet annually, and comprise most of the Russian Rivera summer flow. The National
19 Marine Fisheries Service has deter:nined, in a Draft Biological Opinion issued in January,2000,that
20 continued diversion of Eel River flows to the Russian River jeopardizes the survival of Chinook and
21 echo salmon, and steelhead trout, within the Eel River, in violation of the Federal Endangered
22 Species Act (16 U.S.C. 31531 er seq.). These diversions also harm the salmnaids of the Russian
23 River, by stimulating unnatural populations of warm water fishes that prey upon juvenile salmcaids.
24 2. The SCWA Applications violate Water Code sections 1051 and 1201 because-SCWA
25 lacks any consumptive water.right to.water diverted from the Eel River. Yet most of the Russian
26 River's summer flow currently diverted by SCWA, and proposed for diversion under the SCWA
27 Applications, is diverted from the_Eel River.
28 3. The.SCWA Applications would violate Water Code. sections 1253-58 in that the
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03%28/2001 -09:13 ' 707-555-2624 SG CO CGGSNTY CCUNS=L FnC-E 05/12
1 appropriations con flict•with the water quality objectives and other requirements of the North Coast
2 Basin Water Quality Control Plan'by depriving the SelRiver of flows essential to fish and wildlife,
3 and altering natural flows of the Russian River, thereby harming dependent-public trust resources and
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4 recreational and commercial activities. .
5 4. The SCWA Applications would conflict with this Board's Decision 1510. If SCWA's
6 proposed appropriations are approved, the minimum flows for the lower Russian River snartdated in
. 7 . Decision 1610 could not be maintained daring dry and critically dry years, as documented in
8 modeling studies conducted by SCWA and others. This Board's Decision 1610, in turn, must be
9 reconsidered and revised to reflect the unacceptably severe adverse impacts of historic diversions of
10 water from the Eel River. This Baud failed to consider the adverse impacts of these water diversions
• 11 on the Eel River and its sal:aoaid fishery when it adopted Decision 1610. Curtailment of the Eel
12 River diversions as required under the Endangered Species Act will markedly reduce the quantity of
13 water available within the Russian River for use by SCWA and others, requiring reductions, rather
14 than allowing increases, in the quantity of water diverted by SCWA.
lc 5, The water appropriations proposed in the SCWA Applications would violate the
16 California Environmental Quality Act ("CEQA," Public Resources Code section 21000, er seq.) in
' 37 that this Board's approval precedes; rather rhar follows, certification of an adequate envixonmental
18 impact report('Era") thereon.,SCWA's ETRon the SCWA Applications fails>0 describe adequately I
19 this project and its environmental ef<ecG, alternatives and mitigation measures, and the project's
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20 ; relationship to and inconsistency with applicable land use and water gi:aliry plans and other
21 environmental laws.Accordingly, this Boardshould exercise it n±ority under 14 C.C.R. §150.96(!!)
22 • to reject SCWA's FIR and prepare a subsegcent or supplemental E1F to remedy the deficiencies of
23 SCWA's E .
24 6. The SCWA Applicat ins ignore alternative sources of water for the urban growth that
25 SCWA proposes to serve such as (1) restoration of the Russian River's aquifer by removing gravel
26 mining from the:Russian River and its floodplair9 and restoring the natural snreambed elevation and
2'7 gadient of the Russian.River, (2) conservation water pricing. and (3) constraint-based sustainable
28 growth policies.
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nn"-.-rT n.- rnr->rnc nr,artrr 7.7.1" VWP cT pi 3
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7. The SCWA Applications would, if approved,harm the public interest and public trust •
2 resources-by unleashing explosive, unsustainable growth throughout Sonoma and Mann Counties
3 without any consideration of the cumulative, regional impacts of this growth on the region's open
4 space, fish and wildlife, traffic and highways, air quality, water quality, noise, and infrastructure
• 5 facilities and services such as schools, ?olive, fire, sewer, solid waste, hospitals, etc.
6 d, ' The SCWA Applications are premature because they are based upon a putative service
7 agreement with SCWA's customer ase`ci_s even thous not all of these agencies have approved the
8 agreement. SCWA has failed to provide these contracting agencies with all disclosure of the
9 environmental and economic impacts of its Applications. For example, SCWA has failed to disclose
10 that without any public notice, public hearing or environmental review,on August 8,2000 it entered
11 into an agreement with Pacific Gas and Electric Company potentially obligating SCWA (or its
12 contractors) to as;umv liability for the potentially huge costs of environu?earal remediation of the
13 Potter Valley Project in return for the Water Agency's continued receipt of Eel River via thatproject.
14 SCWA's contractors have never been afforded an opportunity to evaluate this potentially exaerne
15 liability. If SCWA's contractors are afforded an opportunity to evaluate this agreement, they might
16 choose to reduce their future demand for water or reduce their r eliance upon the Eel River diversions,
17 rather than assume the potentially extreme liability that this agreement would impose.
18 9. The SCWA. Applications would impair the protestants' Constitutional right to access,
19 navigate, fish from and otherwise use and enjoy the Eel and Russian Rivers, contrary.to Art. I, §25
20 and Art. X, §4 of the California Constitution, by over-appropriating the waters is these rivers,
21 10. The SCWA Applications constitute an unreasonable use, method of use and method
. 22 of diversion, contrary to Art. X, §2 of the California Coostirucion and §I00 of the Water Code.The
23 proposed anpropriadons are unreasonable because: •
24 (1) SCWA has failed to disclose and address in as ElR or otherwise the severe
25 adverse impact of its water program an the endangered saloon and stet:theact of the Eel River;
26 (2) SCWA has failed to conduct a comprehensive study of alternative sources of -
27 water, including water conservation: •
28 (3) Sonoma County has failed to complete an adequate general plan and
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03/28/2001 09: 13 707-565-2624 SO CO COUNTY COUNSEL FAGE 1-
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1 implementing ordinances designed to assure efficient water use and to curb the premature urban
2 sprawl which this water appropriation is designed to promote;
3 (4) neither this Beard nor SCWA has prepared an adequate EIR evaluating
4 reasonable alternatives and mitigation measures to SCWA's proposed water appropriations; and
5 (5) the environmental damage and recreational losses which may resuir from the
6 proposed appropriation pose a much great= threat to ;b:public interest, including the extinction of
7 endangered coho and chinook salmon and steelhead trout of the Eel and Russian River systems, and
• B destruction of the North Coast's spar. and commercial fishing industry, than would the restrictions
• 9 on urban and suburban growth which would 1 1r from this Board's denial of the SCWA
10 Applications.
11 pESCRWTION OF PROTESTANTS,
12 Protestant Friends of the Eel River("FOER")is a non-profit corporation organized under the
13 laws of the Seale of California in 199E for the purpose of protecting and restoring the natural,river
14 flows, riparian vegetation, and dependent fish and wildlife resources of the Eel River. FOER is .
15 composed of approximately 400 members, who use the Eel River for recreation, scientific study and
16 aesthetic enjoyment. FOER's address is P.O. Box 2305. Redway, California 95560. SCWA's past
17 and proposed future unlawful diversions and consurapdve uses of water from the Eel River harm
18 FOER's members by impairing their use and enjoyment of these waters.
19 Protestant Friends of the Russian River("PORK")is anon-profit corporation organized under
20 t the laws of the State of California in 1993 for the purpose of preserving, restoring ocrt enhancing the
. 21 natural systems, economic resources and public trust values, of the Russian River. its riparian
22 corridor and the watershed that susrairt it. FORR seeks to achieve these goals through citizen acdon,
23 public education, scientific research and expert advocacy. FORR has over 200 individual members
24 and over 30 organiatinnel members who use the Russian River and its watershed for recreation,
• 25 scientific study, aesthete enjoyment and domestic and economic purposes. FORR's address is P.O.
26 Box 1903,Sebastopol, California 95473. SCWA's past and proposed future unlawful diversions and
27 consumptive use of water;from the Eel and Russian Rivers harm FORR's members by impairing their
28 use and enjoyment of these riven and their watersheds.
. PROTEST OF FRIENDS OF THE EF—RIVER, ET AL. 5
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03/29/2001 09: 13 707-565-2624 SO CO COUNTY COUNSEL` FACE 03/13 '
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Protestant Pacific Coast Federation of Fishermen's Associations ("PCFFA") is a non-profit. •
2 • ax-exempt corporation organized under the laws of California and headquartered in San Francisco.
3 Founded in 1976. PCFFA is a'coalition of 22 fishermen's organizations from throughout California,
4 with a combined membership of more than 3,000 fishermen. The PCFFA's principal purpose is to
5 further the protection and restoration of Pacific Coast'
oas waterways•so as to serve the best interests of
6 corny rcia! fishermen. To this end, ?CFFA advocates proper watershed management to assure
7 conservation and restoration of the Pacific Coast's fishery resource. SCWA's past and proposed
8 future unlawful diversions of water tom the Eel and Russian Rivers harm PCFFA's members by
9 damaging salmon and steeihead habitat in the Eel and Russian Rivers, resulting in reduced
10 escapement in those rivers and a corresponding reduction in the allowable catch off shore.
11 ' • Protestant California Sporrfuhin' Protection Alliance ("CSPA") iS a nom-profit corporation
12 organized under the laws of the Star_ of California. The address of CSPA's primary office is P.O.
13 Box 357, Quincy, California 95971. CSPA has thousands of rrem.bers who reside and recreate
14 throughout California. Members arc citizens who, in addition to being duly lic°cnsed spar fishing
• • 15 i anglers, are interested in the preservation and enhancement of California's public trust fishery •
16 resources and vigorous enforcement of California's env±_onmental laws, CSPA members bave'been
17 involved for decades in public education and advocacy efforts to protect and restore the public lust •
• 18 resources of the Eel and Russian Rivers. CSPA members.use the Eel and Russian Rivers and their
• 19 tributaries for recreation,scientific stud;and aesthetic enjoyment. SCWA's past andproposed:Ural e
20 unlawful diversions and consumptive use of water from the Eel and Russian Rivers harm CSPA's
21 members by impairing their use and enjoyment of these rivers and their watersheds.
22 Protestant W iyot Tribe of the Table Bluff Reservation is a tribe of Native Americans who Save
23 lived along and derived their livelihood from the Eel River for many centuries. The name of this
24 •Tribe, "Wiyct," is the W;rot name for the Eel River. After the Eel. River was dammed and its
25 summer flows diverted to the Russian River in the early years of this century, its once-abundant
26 salmon and steeihead fishery, on which the Wiyot Tribe had become dependent for food and
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27 commerce, collapsed. hs a result,the W yot Tribe and Its members were forced to move from their
28 ancestral lands and to seek new livelihoods elsewhere, severing the Tribe from its cultural heritage.
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PROTEST OF FR WS OF THE ZEL RIVER, ET AL. 6
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1 Remaining *iemb rs'oiahe Tribe have formed,asmaliteservanon in Humboldt County at-the Mouth
2 of:the.Eel,River, denotranated the Table Bluff Resetvatieh. 18CWA's past and ;proposed, future:
3 nnlaw,ftil diversions and:consuwrtive uses of water frorn,the,Eel River harm,the Wiyot Tribeland its ; •
4 mernoers by'impairing theirhse,and'enjoyirentlof the...7:er the River?and,its fish and resources.
5 • 'Protestant Coyote'(F;ed Downey, Ph.D.) is a Native .American who resides. as did his
6 ancestors' for many,'centuries, ;in the ttead'W ter-country Of the Eel River; uascream of the Potter
7 Valley Project's'darns end:diversion works that shunt Eel River water to the East Fork RussianRiver. . .
' 8 Until constroctieu of the Potter:Yalley Project a ancirtheifeSUltia destruction of the Eel River and its
ery, ' y . •
9 salraon.and ste°lhead;fish„ G•o ote s tribe,]ivied alon;;ahe banks ofthe upper of the Eel
10 River, and seeured-their,sustet ance from the Rivers''fishmnd wildlife: Coyote has been unable to i .11 restore and'celeorate his tribe's ancient•'ays:of living-and interacting-with'the natural world because .
• 12 the Potter Valley Project block •the,Migration of.salmonids to the Eel.River's upper watershed,
13 eliminating:its anadronods fishery. SCWA's•past_and.proposed;:future.unlawful diversions,and l
14 I consumoiive use of water from;the,Eel•Riyer harms 'Coyote by`iirpairing his use and enjoyment of
. 15 the Eel River and its fish and u•ildlife :esources:-
16 Protestant L;. Martin,Griffin, M,D., is a farmer who•ressides'adjacent;!to the Russian River in
17 Sonoma County. Dr:;Gri fb;vas a co-founder of Protestanr Fricads;of the Russian River in 1993,
18 and is the author of of'SaAnkithe,ManiaThionarna Coac;:,a chronicle-of the many environmenralrtbatt!es.
19 -Dr. Griffin.led during the past:30 years:to protect'end'restore;the wildlands and waters of Marin,
20 Sonoma, Mendocino.and:Humboldt Counties. Dr. Griffin and his fPrn ly use the Russian and Eel
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21 Rivers.and:their watersheds for-recreation: nature study and&aesthetic•enjoyment: In particular,Dr.
22 Griffin has been,an avict:fly i;;herman and canceist an these rivers for several.decades. SCWA's past,
23 and proposed.future unlawful diversions'and consumptive use of water from the Eel and Russian '
24 ,Rivers harm Dr. G tifm and his family oy impairing heir use and eajoymentof these Rivers and their
25 fisu.and'wild ire resources.
26 Protestant Fraile.Egger is a Ceuncihnember of thetoWn of Fairfax in Marn County:. Mr.
27 Egger.has berm an au?poken advocate for protection of the. resources of Mann,Sonoma,
28 Mendocino''and'il ?ioldi,countiesrfor manydecades. :Mr. Egger-is sa co-founder of Frienda:.ofthe
vunrrrcT nu t rFUnc9(;nc THP.. F.71. RWWFR FT AI_: 7' I
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1 Eel Rhreti. and has been actifein:echicaiiiia-',ihe Citizens off.airfaxeana other communities regarding
2 , 'the:ne-ed'to restore the Eel and'kussiari:P:ifeis', nanzrai flows and fish and wiLdlife fesourcet. ll..,11-,.
1 '3 EggerusSithe Eel andiRusiii:Sivers fOrtebrention,nature study and aesthetic erijb9merm,$CWA,'s'
4 pasi,arid proposed future diversions and consumpdveuse of wafer from the &l:and Russian Rivers
harm,Mr.",Egger•by impairing use:,and e.nloyment,fof,ziese!WaterS,,ind by stimulating,explosive
itAan spriwl throughouiiSprioma.aedl\labiii,CUnties.
7 , In addition to the interests described' hereittaboC4, each organizational Protestant' his an
; organizationai interesvinTroitiing iis catinberS and the public with theinfOrinatibb which CEQA . .
9, requires StWA;IO compile ind;to discroselinaif,EIR on theSCWA,4,pplieations. Irotestaith and
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10 their:organizational members have 41right under CEQA to review;and,doihinentitonprojects which • '
' 11; •;tritiyhave a,signifinveffect on diekeavcronment Stich as the•SCW-k,ApplicatiOnS. 1T724e intifett ;
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12 of PrbteStants'and their mernbersthave been hirritedthrSCWA'sifailure to prepare au adequate EiR
11;: •.,end■otherve to cort3ly with'd'EQA., . . . .
., 14. ... .... Rzetitt-15'RELiEF' - . . .
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For the foregoing otng IeaSOns,:iht.SPINA A,pplications are tail aWfdlatidn contrary to the Cala°rm a . .
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16 Constitution. Accordingly, ,peciiitanis request that this Board';:reject'iliel'SC*.A 'Applieltitin.S.
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' . 17' ; Protfabants'request that tas 136ard,conveneiaiii=e1;identiary hearing to'affer&protestants at •.
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I8" I opportunity no present evidinEe establishing that the SCWA Atiptieltion are tin,laidlil in the
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1'9' foregoluelikidts.
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20 , Profes*nts;:reeweet -Tardier that this Boiirddrnmecliaieiyake'appropriate,regulatory. avian,
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":-21 includ int".out not Iiiintedio recalls ieler4op of itsDecisithn 1610, to reitdrecand,prbiecitheef.R.lycrc
22 anctits,publiecust,resources.,
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PROTEST OF FRIENDS OF EL RIVER, ET A.I.::, .
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1 Protestants request further°dat this Board take appropriate,action to assure that the,Russian
2 Rivers public trust'resonr es are°tnanaged in a way to assure their restoration and protection despite
3 curtailment ot'elirnination of-the,exsting unlawfuldive: ion:of water from th Eel River! i e `
4 Dated; September`I2 2000 •
5 Respectfll;.sub* ted,
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B CHER di OLS ",1 LP. --.a%
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I3Y: C (11---,
I STEP _AN C. 'v'GLKER • •
9 Attorney for Protestants Friends of the Eel River, e: al.
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j PROTEST OF FRIENDS'OF THE EEL RIVER, ET 41--.. . .9 ` •
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03/28/2001 09:13 707-565-2524 SO CO COUNTY COUNSEL PAGE 12/:13' •
PAGE 12/12. '
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1 PROOF OFlSERYICE -._
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I hereby declare chat I am a Um,ed States citizen over the'age o;.18%years andFarz'not'a party •
3` to she within=proceeding, My business 3ddressyis 43614th Street, 'Suue 1300, Oakland. California.
4 ,Da.-September 12; 2000 i servea a true and correct copy of,the.foregotng docurrent enticled
5 PROTEST OFflIENDS OF T HE.EEL RIti'-ER FRIENDS O:=IRE RUSSIAN'RIVER, PACIFIC'
COAST FEDERATION OF FISHERMEN'S ASSOCI.A_!'IONS, ,CALIFORNIA S'PORTFISHING
6 PROTECTION ALLIANCE, O' _""
?v1YO,T iRIF3E;OFTH,'-,T.4BLE,B�:UFFRESERVAT?ON,it
rw,,„.p. - - (FRED DOWNEY,,PS.D.)•, L.,MARTLV'GP:IFFIN, NI D. andyFRANK EGGER by firs`i-class mail
addressed to
a,
Sonoma Coanty \Niter Agency' -
9 e/o Randy'D: Poo1e -
General Manager/Chief Engineer• I.0 P.O..Box 1'1'628,, .
' •- I'i Santa,Rosa.CA .95405.
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2' Kenyatte Williams -
. 33 StatefWater,Resources Conifol Board ,
Dtvis ion iof-Water Rights. -
1'4 P,-.-0.,F3ox 2000
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Sacramento; CA 95812-2000' -;•z_5 -
16 erttrYo' i adez p etal� o
perJ 'tactic foreoin is: rue and corct. Executed+on Sepren b `ta
12, 2000 atOakiand,
Ca.ltfornia.
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02/242091 65:I13 707-565.-2624. SO CO COUNTY COUNSEL PAGE i371 2'
PaGS dl/12
law 0(nce3 of
SfEPKAN'C„V&KER ae Nn.11.116
• 436a4 1 Smear Suitel1300
loakland tcellforje 94612
TEL:,5i.0/496108004.F X 51.0%26=,366. -
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DATE: March 26, 2001
To: Nadananda FM:- .?07/923-1902
TEL: 707/923-2146
i
David Keller FAX '707/781-9544
TEE: 707/763-9335
•FROM: StephamC: `Volker '
PAGES: 124ncluding cover sheet
• COMTAENTS; -- ---
1
t Re: Letter TO Tirn'Sinith, lair. Board of Directors of,SCWA re objections o Eleventh
. Amended Ag eementifor Water Suppl% and Ratificacioniof Execution of Agreement
• (Agenda Item,No.,4, Mare!..27, 2001) -
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FACSIMILE'TRANSMITTAL SHEET' • , ■
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. NOTE The;tnforrrarion contained In this facsimile message It:attorney privileged and confidential information
intended only_for the use of the individual or entity named above if the reader of this message 6•not`she
intended redplenc,you are hereby notified that any dissemination,distribution orw communication.
of
dy {.
Is stiicrohlbited. If you.have received'thh communication in error, pleaseitunedla ely notify us`by
telephone, and r tsIm the anginal of this transmittal to us at our address via the'U:St,Postal•Service- Thankyoul
• • .