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Comments from Roger Dingman – Print version

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Comments on Ric Davidge’s Answers

by Roger Dingman

Comments on the answers given by Ric Davidge to the questions asked during The Sea Ranch forum.

Project Ownership, Organization and Relationships

If Alaska Water Exports does not plan to sell or transfer water rights if they are granted, it would be helpful for that commitment to be written into the permit.

Project Overview

1) In earlier discussions (KZYX, KPFA, Sea Ranch Forum), Davidge advised that the water extraction would have “no effect on surface flows”; he now states that there “should not be any measurable harm”. We should know which is the correct answer before the project is approved.

2) There are several references in the answers to additional sources of water other than the Albion and Gualala Rivers. These additional sources would be particularly important in a drought year if Alaska Water Exports had contracts that it could not fill from reduced Albion and Gualala flows. These additional sources have not been identified, but should be in the project application so that the viability of the project in a drought scenario can be assessed. Additionally, comments from residents in those watersheds would be valuable.

3) Also on the subject of dry years, Davidge refers to storage backup apparently at the end user. If this storage backup is part of the overall project, the construction of a facility or guaranteed space in an existing facility would need to be part of the project proposal.

Project Economics

1) If there is not enough profit on the current permit proposal will Davidge increase his diversion amounts to put him back in the black? After five years will he be allowed to ask for more water?

2) Alaska Water Exports needs to identify where a similar project is being operated profitably so all concerned will know that we are not starting down a road that will lead to Alaska Water Exports asking for more water or other concessions so they can make a profit.

Project-level Miscellany

1) The water is not harvested as it leaves the river into the ocean. It is harvested when it enters the system at THE INTAKE. After it is in the pipe, its hydrological dynamics are completely separate from the hydrological dynamics of the river. By isolating it from the dynamics of the river it no longer plays a part in the hydrological scheme of the river. It no longer aids in the transport of sediment, scours holes in the riverbed, aids aquatic creatures in their migratory habits, affects the transport of nutrients, etc.

2) Davidge stated: “Remember, a ten percent water savings through conservation in only one industry, agriculture, could solve the water problems of California for the next one to two decades.”

A 10% reduction in water usage is a good idea. Before the water gets to leave the north coast, any destination for our water must have a conservation plan in place and proof that it has created a “savings of water”. All the recipients of that water must be on metered flow at the point of usage. All agriculture and industry that uses water from the same source or from sources that could be used by the buyer must have a successful water conservation plan in place and be able to show the degree of success of that plan.

3) The bag system is also a fixed facility, only the bag itself is mobile, and subject to flood, earthquake, and terrorist attack. His facility will expose our town, neighborhoods, river, and watershed to that same terrorist attack.

4) The water bag system could not be repaired as quickly as Davidge would like us to believe. To replace a pipe line in winter flood conditions would be impossible. He would have to wait until low flow to get machinery in and DFG may (or may not) make him wait until the fish have quit running for the year.

5) Where is the science that shows long term bag/tug operations have fewer ecological costs than desalination, upstream diversions, or dams?

On-Shore Environmental Impact

1) Davidge states: “By placing the cistern and pipeline in the bed, we remain within the river’s hydrology.”

I have shown this statement to geologists, hydrologists, engineers, and marketing specialists. The common opinion was that this is one of the most nonsensical descriptions they had ever heard. One of them called it “deceptive bull shit” — strong words, coming from a professional! Although technically true (yes, the pipe is between the banks and in the subsurface flow therefore in the “hydrological system”) this statement is, realistically, very deceptive.

The water is in a pipe and SEGREGATED from the flow. Davidge admits this. It travels at a different speed and rate. His pumps can change the flow rate of the water at any time. He can make it go slower than the river or faster than the river therefore it plays no part in river hydrology what so ever. It has no effect on the scouring of the turns in the river, the pools in the river, or the riffles in the river. All aquatic life, surface, subsurface, and substrate (in the gravel), is denied access to this water.

2) His siltation (installing the pipe) will do more damage than the high flow events. During high flow events silt is transported through the system and to the sea. High flows tumble the gravel at the bottom of the river and release silt. As the flow slows the silt is redeposited in the gravel. This is how water works. The slower the flow, the smaller the material is that gets moved. The bigger the flow, the bigger the material is that gets moved. Prolonged big flows move larger material farther distances.

The gravel depth he intends to dig (five feet) contains large amounts of silt, clay, and sand. By digging in this gravel layer at low flow, there will be no chance for this silt, clay, and sand to flush through the system. They will drift down stream a short distance and settle to the bottom. Anyone that has watched a summer culvert crossing get pulled out knows this. When this fine sediment settles to the bottom it covers and smothers most of the aquatic benthic macro invertebrates. These are the river bugs: Caddis flies, Mayflies, Stoneflies, Dragonflies, Damselflies, just to name a few.

Fish and other animals use these adult, larval, and nymphet bugs as a “very high protein food source”. When these bugs emerge as adults in the fall, the fish use them as food source to fatten up just before they make their run to the sea. By removing this food source Davidge will cause these fish to go to sea undersize and less competitive for food and less able to defend themselves from larger predators.

3) Davidge shows that he will be taking what we consider surface flow. He has been talking around a technicality in the EPA definition of surface water. The water in the alluvium flows towards the sea just like stream flow, it just goes a lot slower. If he pumps subsurface water and the subsurface flow can not keep up the surface flow WILL be pulled into the intake. In his radio interviews he stated, emphatically, that his project would not effect surface flows.

4) The installation process will not be as benign as Davidge portrays. I have participated in a project that dug in this gravel. As a wet material the walls will continuously cave in until it reaches it’s own angle of repose, about 45 degrees. He says his trench will be 5 feet deep. That makes the top of his trench approximately 12 feet in width: (5+5+2.5=12.5). This is a significant amount of material to be moved. The silt and clay that would be reintroduced to the water flow would be devastating to the system at such a low flow period.

My experience has taught me that one piece of equipment will dig the trench. It will have to be large enough to stay far enough away from the trench so as not to fall in while digging. Probably a large excavator will be used. Crews will assemble the pipe on the ground next to the trench. By his claim it will be high density polyethylene which is very similar to poly vinyl cloride. They will slide the 20 foot lengths together and then lift the pipe into the trench with two or three small cranes. The pipe will be held down by buoyancy blocks. Large concrete blocks placed under or over the pipe to keep it from floating. The concrete might be placed as a wet material and allowed to set-up before burial or as precast blocks. After the blocks are installed the pipe will be covered up. Usually with a bulldozer(s). There will be several large pieces of “heavy equipment” in the river bed at one time.

5) Davidge is avoiding telling us the name of the specific river sediment transport model he is using. Odds are he is talking through his hat. Five to ten year events regularly move the size of gravel he will be digging in. Not to account for these events means that he will be moving heavy equipment for maintenance and repair into the river a lot more often than he is telling us. This will include winter flows that will be higher and more disruptive to the streambed and fish migration.

6) Here again he is not telling the truth with regard to the species that will be affected by the installation, operation, and maintenance of the intake mechanism. Species effected are many and varied. Steelhead and Coho use these reaches to rear for the Summer. By disrupting their rearing habitat he will effect them. By killing millions of benthic macro invertebrates he will effect Steelhead (threatened), Coho (endangered), the Gualala Roach (species of special concern), Yellow legged frog (species of special concern), Skulpin (3 types), Flounder, the Pacific Giant Salamander (species of special concern or threatened), Three Spined Stickleback. Birds; Blue Heron, Egrets, Gnat Catchers, Swallows, Starlings, Sea Gulls, Pelicans, assorted fish ducks, and many types of song birds (all of which are protected). Harbor seals, bats, raccoon, opossum, and skunks. There are many more that can be listed here.

7) Regarding sediment changes in the estuary, Davidge is not addressing what happens when the high flows wash the freshly disturbed gravel off the top of his pipe. By trenching, he will loosen approximately 11,000 cubic yards of gravel. Currently, the gravel is small and compacted with silt and clay forming a relatively smooth surface that is less apt to create the turbulent flows that would normally dislodge the sediment, suspend it, and transport it down stream. However, when loosened or dislodged, it becomes highly erodible and far more susceptible to movement by lower flows. Should the pipe line buoyancy blocks be exposed, they will act like large boulders and large woody debris: heavy scour will take place around the pipe and blocks sending even more sediment down stream. The chances of the pipe line being damaged under those conditions are very high. This would mean using heavy equipment to make emergency repairs to the line during winter flows. Should the pipe line fail (open), large amounts of gravel will enter the pipe and most likely fill it for a long distance. That would mean that the whole construction process would have to start over.

In addition, Davidge seems to believe that our river bed is stable. It is not stable by any means. The river is washing down gravel from the upper reaches and depositing it on the gravel bars and in the channels as far up the river as you wish to walk. As these gravel bars grow in height, the channel becomes more constricted. The more the channel flow is constricted, the more the rivers energy is focused on scouring the channel bottom. The gravel bars at Green Bridge, Switchville, Donkey Hole, Thompson’s Pier, Minor Hole, Mill Bend, and The Island are growing each year. The channel is being constricted more and more each year. It won’t be long before flows will be constricted enough to begin the channel down cutting phase.

In order for Davidge to protect his pipe he will have to bury it much deeper or remove the gravel bars each year to prevent channel constriction. If the pipe goes deeper, there will be more loose gravel to erode, or if he takes out the bars annually, we will never get the channel constriction needed to create a deeper channel necessary for the return of the aquatic habitat required to restore the Steelhead, Coho, and Chinook populations that once existed.

8) Davidge says he is going to harvest water during the “rainy season”. We know that it does not rain every day and that the river flow drops during the periods between the storms. If Alaska Water Exports harvests during these periods, he may very well cause premature closing of the mouth by removing the flow that keeps the mouth open.

Off-Shore Environmental Impact

Large ships did not, historically, enter the mouth of the Gualala River. They anchored between Robinson Reef and the North Point and were loaded by high line. Log booms were floated down stream in high water to be tied to the cribs and small sail boats carried commercial goods upstream 2.2 miles to Thompson’s Pier (Gualala River Redwood Park).

On-Shore Infrastructure

Davidge apparently does not understand the importance of not disrupting the sand spit, and what disrupting it would do to the estuary/lagoon ecosystem. By disrupting it, he could change the opening/closing regime very easily.

On-Shore Operational Considerations

1) It appears from his statement that Davidge underestimates the probability of high maintenance on the intake and pipeline. Our channel will begin to down cut within the next few years. At five feet deep, his pipe will be exposed and need a lot of maintenance. He can not get his pipe deep enough to avoid a lot of maintenance.

2) It might be true that the system should not have a major effect on swimmers and boaters, but there may very well be a major effect on recreation around the intakes. Vandalism is possible, so security must be high profile. Should boaters and such happen to spend more time around the intakes and facilities than the security people feel they want to deal with, then there will be issues of illegal access denial.

3) “Environmental problems” that I foresee: Equipment in the stream to repair and/or replace pipe; the flooding and plugging of the intake and the disposal of the offending material; flooding of the pump chamber and delivery of lubricants to the stream; flooding of the pump chamber and electrical shock (even though momentary) to human life and wild life; failure of the pipe line and disposal of the plugging material; channel shift caused by the natural down cutting process at the intersection of the pipe and the thalweg; damage from the tug being pushed ashore and the associated damage caused by the clean-up; damage from the bag being pushed ashore and associated damage caused by the clean-up; damage from the bag inlet platform form being torn loose, pushed ashore, reconstructed, and the associated clean-up.

4) Not addressed by Davidge are emergency generators that will be needed to power the pumps during the loss of commercial electrical power; there will be potentially objectionable noise from these during operation. Neither has he addressed the fuel storage tanks needed for the generators and how they will be protected from polluting the site.

5) Monitoring should be by multiple parties in order to provide balance. At a minimum, the monitoring should be by SWQCB, DFG, and NMFS with additional monitoring done by various local groups. It is important that monitoring entities have full access to all phases of construction and operations.

6) We will need to see the final design to make comment on its visual impact.

Non-Environmental Impacts

1) The design change to which he refers is to move the loading facility to the southwest corner of Gualala Island. It will still be visible from town and from The Sea Ranch bluffs.

2) Winter tourism is on the rise. People come here to watch the storms and to get away from their own winter drudgery at home. For the last two years, fisherman have been catching larger fish than in the past. This could mean an increase in the number of fisherman and the dollars they spend during the winter months.


Mr. Davidge claims to want to do whatever we want to make his project acceptable. The problem is that the physical nature of his project is the worst thing that could happen to the Gualala River.

To maintain a viable project, he needs the river to sustain its current level of degradation. This is not possible. Natural processes, even without restoration efforts, will in time turn this river into a deep channel again. This would be detrimental to his pipe line and intake(s). Large structures would have to be built and maintained each year to keep the gravel from washing out or the pipeline would have to be trenched deeper every few years (besides annual maintenance) to keep it safe from the winter flows.

By placing grade checks in the riverbed, natural down cutting will be stopped and the deep channel habitat needed for the rearing of salmonids will not be restored. Heavy equipment (and the diesel, grease, motor oil, hydraulic oil, and fluids contained therein) would need to be in the riverbed repeatedly with no guarantees as to whether or not there would be an exclusion period (emergency maintenance must occur).

Disruption of the streambed will cause siltation of the downstream habitat – negatively effecting the creatures in that habitat and the creatures depending on them as a food source. Diversion of flows will change the hydrological dynamic of the river and pose a problem to anadromous fish migration.

Marine structures would be placed in marine mammal migration refuge areas. Harvest is planned when our ocean conditions are the roughest and most dangerous. The amounts of water to be taken only happen for short periods of time but the application does not reflect that in the harvest regime.

Even as a project with “less environmental impact than a dam, peripheral canal, etc.”, Mr. Davidge’s water bag project would be environmentally devastating to the Gualala River and the restoration of a once proud world-class fishery.

Biographical Note on Roger Dingman

Mr. Dingman is a certified Ecosystems Management Technician with extensive experience in riparian revegetation, bank stabilization, and in-stream habitat enhancement. He is currently president of the Gualala River Steelhead Project, the largest Steelhead rescue project in California. He has eleven years of in-depth experience in restoration work on the Gualala River watershed.