The California Department of Fish & Game has published Draft Environmental Impact Reports (DEIRs) for the proposed Scott River Watershed-Wide Permitting Program and the proposed Shasta River Watershed-Wide Permitting Program. If granted, the proposed permits would “Cover” all agricultural operations of participating landowners and allow “Take” of Coho salmon which are listed as threatened under the California Endangered Species Act. The sweeping permit programs would be administered by the Shasta and Siskiyou Resource Conservation Districts which are appointed by the Siskiyou County Board of Supervisors and which are dominated by ranchers and farmers.
The DEIRs for the Shasta and the Scott respectively are available at the Department of Fish & Game’s web site. Comments on the DEIRs are due on or before December 9, 2008. Comments should be directed to:
Mr. Bob Williams
Department of Fish and Game
The public may also submit verbal and written comments at public meetings which have been scheduled on the DEIRs. The Scott meeting will take place at the
Here is how the Department of Fish & Game describes the purpose of the permit programs:
The primary purpose of the Program is to facilitate compliance by Program participants with Fish and Game Code Section 1600 et seq., and with respect to coho salmon, the California Endangered Species Act (CESA) (Fish and Game Code, §2050 et seq.) while conducting specific routine agricultural activities the Program covers. Farmers and ranchers in the Program area may participate in the Program. Other participants include the
Fish advocates are not opposed to the idea of providing farmers and ranchers in the Shasta and
Here are the “fatal flaws” which salmon advocates have identified:
- The permits are designed to cover not just irrigation water diversions from streams but ALL agricultural operations of participating landowners. This includes unregulated activities - including groundwater pumping - which are likely to be negatively impacting stream flow. In the Scott, for example, there is a peer reviewed study (see abstract at the end of this post) indicating that unregulated groundwater pumping (which has doubled since the 1950s and now accounts for about half of all irrigation in the Scott) is responsible for 60% of the reduction in
streamflow. Adjudicated rights of the Forest Service to flows in the Scott for fish are now not met in the late summer and fall even in average water years. Chinook migration is delayed in even average water years; in drought years Chinook don't reach the Scott River and Coho migration has been delayed due to insurmountable salmon migration barriers caused by low river flow. In very dry years the Scott Valley Scott Rivernow completely dries up before it leaves the . Advocates say the Shasta has similar problems with groundwater and that any riparian landowner can pump unlimited amounts of water from the Scott Valley . Shasta River
- The Department of Fish and Game proposes to put the farmer and rancher dominated Siskiyou and Shasta Resource Conservation Districts in charge of enforcing stream alteration permits and the California ESA. Advocates liken this to putting the proverbial fox in charge of the proverbial hen house. They say that the Department of Fish and Game can not legally delegate its permitting and enforcement authorities to locally appointed boards. The Resource Conservation Districts were not set up as regulatory agencies and it is doubtful that their farmer and rancher dominated boards would be willing to enforce rules and regulations on their neighbors.
Here’s the scientific journal abstract of the peer-review study which found that 60% of the reduction in Scott River streamflow can not be attributed to changes in climate and snowpack and are likely related to unregulated groundwater pumping:
Relative Effects of Climate and Water Use on Base-Flow Trends in the
Lower Klamath Basin
Source: JAWRA Journal of the American Water Resources Association, Volume 44, Number 4, August 2008 , pp. 1035-1052(18)
Publisher: Blackwell Publishing
Since the 1940s, snow water equivalent (SWE) has decreased throughout the
Keywords: surface water hydrology; climate variability/change; rivers/streams;
Document Type: Research article
Affiliations: 1: Associate Professor, Department of Mathematics, Idaho State University, 921 S. 8th Ave., Stop 8085, Pocatello, Idaho 83209 2: Research Assistant, Department of Fisheries Biology, Humboldt State University, Arcata, California 95521.
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