Open Letter, Siskiyou

Open Letter: River Minimum Flows

State Water Resources Control Board

California and Siskiyou County farmers and ranchers have already experienced emergency regulation curtailments this year. Shasta Valley farmers and ranchers have experienced a sequence of curtailments: initially a conditional curtailment, followed by a full curtailment, and then a reversion back to a conditional curtailment. The desired minimum flows continue to exceed any scientifically documented data. According to the McBain Trush Study (pg. 106, Table 30), McBain Trush recommends a flow of 40 cubic feet per second (cfs) from April 1 to June 15 and notes that 36 cfs was sufficient in Reach 3 (the Shasta River between Parks Creek and Big Springs Creek). The study then recommends a flow of 13 cfs from June 16 to September 6, followed by 20 cfs until April 1.

Reach 4 is a main stem portion of the Shasta River. If flow requirements in this reach are sufficient for salmonids, then these flows should be adequate for the remaining sections of the river. The requirement of a 50 cfs minimum flow in the Shasta River is burdensome and neglects the scientific data. If similar irresponsible recommendations were made for the Scott River, the required minimum flows there would also be excessive and burdensome. Accurate science and unbiased decision-making are not only your responsibility but also mandated by law.

Minimum flows based on the McBain Trush study should clearly not exceed 20 cfs, except during the April 1 to June 15 timeframe, when outgoing salmonids require increased flow. A reasonable compromise would be 25 cfs, with conditional curtailments at 30 cfs. During April 1 to June 15, the recommended flows by the McBain Trush Study should be followed, setting the flow at 40 cfs, with conditional curtailment at 45 cfs. There is scientific evidence to support these minimum flow standards. The current minimum flow emergency regulations (E-regs) contradict the existing scientific data. Please revise your minimum flow requirements to align with the correct scientific data. Revising these minimum flow requirements would also suggest a review and possible correction of the Scott River requirements, in correlation with the necessary changes to the Shasta River.

Jess Harris
Siskiyou County Resident
Cc: NOAA Fisheries, California Department of Fish and Wildlife, Siskiyou County Board of Supervisors

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