Friends of Gualala River Protecting the Gualala River watershed and the species living within it
To: Nathan Quarles
Deputy Director, Engineering and Construction
Permit and Resource Management Department
County of Sonoma
Email: Nathan.Quarles@sonoma-county.org
Well Ordinance Public Comments
Submitted via email: PermitSonoma-Wells-PublicInput@sonoma-county.org
From: Friends of Gualala River Board of Directors
P.O. Box 1543
Gualala, CA. 95445
Email info@gualalariver.org
Date: February 22, 2023
Subject: Friends of Gualala River comments on the proposed draft Well Ordinance
_____________________________________________________________________________
Friends of Gualala River (FoGR) is a grassroots nonprofit organization that has worked for over thirty years to protect the Gualala River watershed (GRW) and the species living in it.
This memorandum builds on the one that FoGR submitted to PRMD on February 2, which highlighted our questions and concerns regarding the County’s proposed Well Ordinance and the Public Trust Review Area (PTRA).
FoGR retained Greg Kamman a California certified hydrologist and registered professional geologist, who has working knowledge of the Gualala River watershed, to review the proposed well ordinance amendments, supporting materials and to include provisions for evaluation of the impacts to the Public Trust Resources in the GRW. Attached is Mr. Kamman’s letter.
FoGR agrees with Mr. Kamman’s conclusion that the proposed permit screening process delineating the PTRA fails to protect the public trust resources in the GRW “because it does not consider or incorporate the current state of high streamflow depletions occurring in the watershed.” Mr. Kamman describes faults with the methodology used in determining the pumping ratio developed for the GRW. He highlights significant data gaps and concludes that the estimates of groundwater demand/pumping and recharge estimates are underestimated and overestimated, respectively, which “taken independently or in combination will tend to reduce the risk level for stream depletions.”
As Mr. Kamman notes, “the Gualala River is already experiencing severe streamflow depletions more severe than that estimated in the OEI report.” Attached are photos taken in 2021 affirming this fact. And FoGR agrees with Mr. Kamman’s conclusion that due to the flawed working proposal methodology for delineating the PTRA on the Gualala River and its tributaries, “a watershed-scale analysis that evaluates the existing and proposed cumulative impacts from pumping and changes in recharge is warranted to determine areas that are protective of streamflow depletion.” FoGR requests that the County select The Rohde Proposal, or similar, for the well permit screening process.
FoGR would be happy to discuss our concerns and requests with the County further. Thank you for your attention to FoGR’s input concerning this critical policy approach.
Sincerely,
Lynn Walton, Vice President
Friends of Gualala River
