In addressing the “science” being used to determine the minimum in-stream flow restrictions for the Shasta River, similar to the Scott River. The latest study used for determining in-stream flows is the McBain and Trush habitat study called “Shasta River Big Springs Complex Interim Instream Flow Needs Assessment,” conducted in 2013.
The study explicitly states that
“minimum flows will not meet population and community fish health and should not be used for recovery.”
It also notes that
“No single minimum streamflow provision can accomplish all the complex hydrological and biological functions equally.”
Despite this, the State Water Board persists in using outdated information and refuses to acknowledge the study’s content. The study highlights the differences in requirements for Chinook salmon, Coho Salmon, and Steelhead Trout, emphasizing that conditions optimal for one species may be subpar for another. Insisting on “trying to correct nature” has been destructive to our county and its ecosystems. The study also assesses fish survival based on stream depth and velocities, rather than relying solely on instream flow numbers. The State Water Board needs to admit its incorrect application of a habitat study and cease advancing inaccurate instream flow proposals.
Concerning water temperatures, the study indicates, “Water temperature results are one dimensional and do not account for isolated, local thermal refugia, which may play an important role in salmonid LHT’s in the Big Springs Complex.” Water temperatures during specific times of the year are determined by nature and the current climate, beyond the influence of any entity, including the State Water Board. No amount of regulation can alter these temperatures.
Reviewing the minimum instream flow numbers outlined in the study, none of the Priority Reaches exceed 15 cfs during the June-September time frames, with most below 10 cfs. Low total summer and base flows range from 30-50 cfs outside of drought conditions. Setting the minimum flow at the high end of the spectrum during drought years under an “emergency order” seems unwarranted. The minimum flow should be set at the low end of the spectrum during normal years, not exceeding 30 cfs. Setting the minimum higher than 30 cfs would be irresponsible and neglectful. I urge the State Water Board to apply science honestly and accurately.
My comments at the listening session in Montague, CA to the State Water Board Committee stated that the State Water Board needs to define the existence of an emergency and when the regulations would be in effect. Emergencies decared on a whim are reckless, highly political, and detrimental to all. Curtailing water rights without a clear explanation of what constitutes an emergency is in conflict with court-ordered water rights and susceptible to litigation. The State Water Board should not to pander to special interests and political pressure. Proper management is achievable only through the responsible, honest, and transparent work of the community involved and the assistance and support of the State Water Board.
Jess Harris
Siskiyou County Resident
530.6*3.9084
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