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I am submitting these comments relating to the Draft EIR (DEIR) for the Fish Habitat Flows and Water Rights Project written by the Sonoma County Water Agency. I have reviewed the Draft EIR and am very concerned about how the proposed flow reductions and schedule will worsen the baseline “significant and unavoidable” water quality impacts from Biostimulatory Substances with “no mitigation available” (DEIR, Impact 4.2-4.) This is not acceptable because this water quality impact negatively affects not just human recreational use but will potentially reduce concentrations of dissolved oxygen that could harm the very species the DEIR claims to “improve habitat” for. Increases in the concentrations of Biostimulatory Substances will certainly occur due to lower dilution so this project will produce secondary negative impacts to fish, especially when the Biostimulatory Substances end up in a closed estuary that already has high concentrations of phosphorous.
There are several alternatives to the proposed flow schedule reductions in summer minimum flows that would reduce impacts to Biostimulatory Substances and temperature and the DEIR must evaluate feasible alternatives to comply with CEQA law.
In order to reduce predicted significant and unavoidable water quality impacts, the Final EIR for the Fish Habitat Flows and Water Rights Project should evaluate the following feasible alternatives to the flow reductions proposed in the DEIR. These alternatives will meet Project Objectives to preserve the cold-water pool in Lake Mendocino and reduce mechanical breaching of the sandbar at the Estuary.
Implementing these alternatives would provide the following benefits: