Review Comments, Draft Environmental Impact Report Fish Habitat and Water Rights Project

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1 MEMORANDUM 7 Mt. Lassen Dr., Ste. B250, San Rafael, CA Telephone: (415) Facsimile: (415) greg@khe-inc.com Date: March 8, 2017 To: From: Subject: David Keller, Friends of Eel River Greg Kamman Review Comments, Draft Environmental Impact Report Fish Habitat and Water Rights Project This memorandum presents a summary of comments developed during review of the Appendix G (Russian River Hydrologic Modeling for the Fish Habitat Flows and Water Rights Project, August 2016) to SCWA s Fish Habitat and Water Rights Project DEIR. These comments are organized pursuant to the numbered hydrology related categories below. 1.0 Eel River Diversions and PVP a) Page 2-9 of Appendix G to the DEIR states that annual PVP diversions now average 67,000 AF. Analysis of baseline PVP diversions integrated into the ResSim model yields an average annual diversion rate of 76,800 AF and median annual diversion rate of 80,250 AF. Figure 1 below plots the average and mean monthly PVP diversions used in the baseline ResSim model note the relatively high diversion rates during summer months. The modeled PVP diversion rates are significantly higher than the stated PVP diversion rates and the inconsistency between reported and modeled values should be corrected or explained in the DEIR. b) Page 1-7 to 1-8 of Executive Summary states, The Proposed Project does not propose to increase or otherwise change the quantities of water that it diverts from the Russian River and Dry Creek and re-diverts from Lake Mendocino and Lake Sonoma under its water right permits, obtain any new authorizations for new rights, or construct new facilities. In other words, the project will keep diverting water from the Eel River and depend on PVP and Lake Pillsbury operations (i.e., in essence, the PVP an associated reservoirs are an important infrastructure element to Lake Mendocino and Russian River operations). Figure 2-5 of Appendix G indicates that the Eel River diversions account for approximately 50% of mean annual inflow to Lake Mendocino. As part of cumulative impact assessment, the DEIR analyzes the scenario of eliminating diversion from the Eel to Russian River. It is my understanding that there are potential dam safety issues associated with Scott Dam 1. 1 See letter report from Miller Pacific Engineering Group to Friends of Eel River entitled, Preliminary geologic and geotechnical evaluation, Scott Dam (Lake Pillsbury), Lake County, California, and dated March 1,

2 Acre-Feet (AF) The DEIR does not address dam safety or potential dam-break flooding impacts on the Eel River regardless of maintaining or eliminating out-of-basin diversions. Monthly PVP Diversions 10,000 9,000 8,000 7,000 6,000 5,000 4,000 3,000 2,000 1,000 0 JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Average Median FIGURE 1: Average and median monthly PVP diversions from the Eel River calculated from baseline ResSim model data. 2.0 Hydrologic Index Page 1-6 to 1-7 of the DEIR Executive Summary indicates that the Hydrologic Index is used to characterize water year types and associated minimum instream flow schedules. The Hydrologic Index has been shifted from Lake Pillsbury (unimpaired inflow) to Lake Mendocino inflow (a large portion coming from Eel River diversions) and storage to better reflect local hydrologic conditions. The old index is based on unimpaired flow totals to Lake Pillsbury, while the new index is based on a combination of diversions from the Eel River, natural inflow from the East Fork Russian River and storage in Lake Mendocino. The character of the index has shifted from on controlled by natural inflow to one controlled by a managed reservoir inflow and storage. The Hydrologic Index is used to establish water-year types for Russian River instream flow release (5 year-type flow schedules). The index reflects upper basin supply in Lake Mendocino, which is primary source of water for the River upstream of Dry Creek. Interestingly, Lake Sonoma is not factored into index-derived flow schedules downstream of Dry Creek the determination of flow schedules on both the upper and lower Russian River are based on inflow/storage based Hydrologic Index for Lake Mendocino only. Therefore, the Russian River flow schedules have a dependence on Lake Mendocino hydrology both upper and lower River flow schedules controlled by Lk. Mendocino inflow/storage while 2

3 releases from Lake Sonoma are used to make up the difference when Lake Mendocino releases alone are not sufficient to meet minimum flows and diversions. The ability of the project to meet flow and water supply objectives is constrained by overreliance on Lake Mendocino storage. A logical alternative to avoid impacts that stem on this reliance would be to direct Lake Sonoma water releases to a location further upstream on the River enabling Lake Sonoma supply to play a more active role in meeting Project objectives and reducing the burden and impacts on Lake Mendocino. Lake Sonoma storage is much greater than Lake Mendocino and DEIR analyses suggest that Project operations do not impact Lake Sonoma storage levels and supply to the degree predicted on Lake Mendocino. Redirecting Lake Sonoma water further upstream would be an expensive endeavor, but the benefits of such an action are worthy of analysis under CEQA and the DEIR should include such an alternative. 3.0 Lake Mendocino Operations The minimum instream flow compliance buffer is described on pages 2-23 through 2-24, in Appendix. G of the DEIR. Buffers are additional water released to insure instream flow requirements are satisfied. Historically, due to variability in reported flow estimates at USGS compliance point gauges, extra buffer releases were made. However, a 2010 petition from SCWA to the State Board requested a 5-day moving average compliance to minimum flow requirements with an instantaneous flow compliance floor (I don t know what this quoted portion of sentence means). The 5-day moving average compliance allows SCWA to reduce buffer flows. I did not identify any application of buffer flows in the ResSim model. It is unclear to me if river flows can drop below the minimum flow requirement during the 5- day average period, but this seems like a logical possibility given the need and intent for a 5- day average. I understand the intent to provide reasonable flexibility to water operations and conservation, but deficient flows during some portion of the 5-day period or large and rapid fluctuations in flow rates could have adverse impacts on aquatic habitats. The DEIR should include a statement of if and when flows would occur below the minimum instream flow rates and associated potential impacts are to biological resources. 4.0 Water Losses (Flow Depletions) a) The ResSim model accounts for agricultural and many municipal water demands on the Russian River (see comment on integrating agricultural water applications into DEIR analysis under item f) below). However, these demands do not account for all of the water losses measured at intervening USGS flow gauging stations on the upper river and Dry Creek (i.e., agricultural and municipal water demands alone do not account for the amount of streamflow loss that occurs from Ukiah to Healdsburg and on Dry Creek for the Months of May through October). Quantification of these losses for the Upper River (Russian River upstream of Healdsburg) and Dry Creek reaches are documented in the 2016 Grinnell report in Appendix G of the DEIR. The excess water losses are attributable to, direct depletion through diversion of streamflow, diversion of underflow, or indirect stream depletion due to stream-aquifer interaction. The ResSim streamflow losses also include demands for frost protection. 3

4 The DEIR does not present any analysis that attempts to quantify or account of the timing and volume of all permitted diversions on each upper River reach for comparison to the streamflow losses. SCWA is aware of these data and have used them for other DEIR analyses 2. Further analysis of this water rights data would provide an understanding for how permitted versus unpermitted diversions contribute to the estimated streamflow losses. As part of the Project, water is released from Lake Mendocino to maintain minimum instream flows and provide water to downstream demands by agriculture and municipal users. Lake Mendocino releases to the Russian River are controlled by frequent observation of flow measurements at USGS gauges. SCWA receives little information from agricultural and municipal diverters to determine the release rate from Lake Mendocino (pg. 2-12, Appx. G). As flows recede during the dry season, the minimum flow compliance point transitions from upstream to downstream flow gauges. The furthest minimum flow compliance point based solely on Lake Mendocino releases is Healdsburg (pg. 2-20, Appx. G). SCWA adjust release rates to meet the minimum flow requirements at compliance points without providing oversight of intervening diversions, which reduce river flow rates prior to reaching a compliance point. The way I understand this, the Agency must release enough water to satisfy known and unknown river diversions and losses in order to meet minimum flow requirements at downstream compliance points. SCWA is obligated to provide sufficient water to meet downstream minimum flow requirements, which means they must also provide enough flow to compensate for intervening diversions, both permitted and unpermitted. Regardless of their jurisdiction to regulate water rights and diversions along the river, the SCWA operations recognize and compensate for undetermined losses in stream flow in order to achieve the municipal and minimum flow objectives of the Project. One mitigation that could reduce impacts on available water supply and Project operations is to better regulate illegal diversions that affect flows within the river corridor. However, a mitigation or alternative to address this impact does not appear to be included in the DEIR. b) It is interesting to note that there are no unaccounted for stream flow losses incorporated into the ResSim model downstream of Healdsburg. This suggests that infiltration loss and groundwater pumping influences are not significant in the alluvial 2 The 2013 Davids Engineering, Inc. (March 2013) report entitled, Russian River Applied Water Estimates Development Report included in Appendix G to the DEIR includes a description of water rights analysis used by SCWA to delineate the Applied Water Analysis Zone (AWAZ) used in the Davids study. This analysis, completed by SCWA, included obtaining, mapping and reviewing the point of diversion (POD) and point of use (POU) locations for water rights along the Russian River and Dry Creek. Water rights information was obtained through the SWRCB ewrims website. They determined that there are 1068 PODs located within the 51,370-acre AWAZ. There is no discussion on quantifying the volume of water associated with PODs, the data appear to have been used solely to assist in delineating the AWAZ. 4

5 reach between Healdsburg and Wohler (the river transitions to a more bedrock dominated valley downstream of Wohler to the Ocean). Given, a) the similarity in the character of the underlying valley fill alluvium both upstream and downstream of Healdsburg 3, and b) the lack of significant streamflow losses downstream of Healdsburg, it could be assumed that streamflow losses due to infiltration are minimal. If true, this suggests that unaccounted for river diversions and well pumping of river-supplied groundwater are the main cause for streamflow losses. This places even more emphasis on the need to account for and better manage the undetermined losses by diversion from the River. Eliminating illegal diversions could change the way the Project is operated and reduce potential adverse impacts associated with project operations. Again, it seems reasonable that the DEIR should address the issue as a potential mitigation measure. c) The ResSim model accounts for municipal diversions, separately from the water loss estimates. Municipal diversions in the ResSim model, include: City of Windsor; Hacienda agg.; Healdsburg Dry Creek wells; Healdsburg Fitch Mountain wells; Redwood Valley; Russian River County Water District; and SCWA diversions. In addition, the ResSim model accounts for municipal/agricultural diversions for several entities from Lake Mendocino. However, I could not find an accounting for demands/diversions in the ResSim model for the majority of the public water municipalities indicated in Table 2-2 of Appendix G to the DEIR (table presented below). It is unknown if these diversions comprise a portion of the stream flow losses described above or are lumped into one of the municipal diversion data sets listed above (esp., SCWA diversions ). The DEIR should clearly state how all the municipal diversions are accounted for in the ResSim model. 3 This similarity is assumed and will be evaluated. 5

6 d) An accounting of stream flow losses and frost protection demands are provided in the table attached to the end of this memorandum (Attachment A). The minimum, average and maximum monthly losses (period 1910 through 2013) for the four upper river reaches (Calpela, Hopland, Cloverdale and Healdsburg) and Dry Creek are presented under the heading Water Budget Loss in the center of each table. Water loss values are in acre-feet (AF). Frost protection diversions occur from March 1 through May 15 of any given year and monthly minimum/average/maximum values are broken out from total streamflow losses and tabulated in the three right-hand columns of each table. For comparison, the minimum/average/maximum monthly river reach flow rates are presented under the heading Baseline Flow. Average total annual loss and flow volumes are also presented at the bottom of each table. The percentage value listed in the cell immediately right of the Water Budget Loss average total annual value in each table is the percent loss relative to average total annual flow. The percentage value listed in the lower right hand corner of each table represents the amount of frost protection water relative to stream flow loss. Interesting findings from these data include the following. 6

7 Streamflow loss rates are highest in the Calpela Reach and generally decrease in a downstream direction. The average March through October total volume of stream flow losses in the upper Russian River and Dry Creek is 37,919 AF. For comparison, the SCWA water right for Lake Mendocino is 75,000 AF/yr. Based on these data and my prior comments under this section, non-permitted water rights and diversions may be contributing to significant stream flow losses. Again, it seems an accounting for these impacts should be included in the DEIR. The average annual total Eel River diversions from the ResSim model are 76,832 AF a value notably higher than the 67,000 AF annual average representative of current demands reported on page 2-9, Appendix G of the DEIR. Average Eel River diversions for the seasonal May through October period are 42,129 AF. The large discrepancy between ResSim model and Appendix G reported annual total diversions should be explained in the DEIR. It is unclear to me why the modeling analysis of Project alternatives is higher than the reported demand. Frost water demands make up all the losses during March and April and part of the loss during May. They range from 1.7% to 2.2% of the total annual average streamflow losses in the Calpela, Hopland, and Cloverdale Reaches, but only 0.5% in the Healdsburg Reach and 0.2% in Dry Creek. The average annual total volume of water used for frost protection in the upper River and Dry creek is 537 AF. The frost protection demands in the Healdsburg and Dry Creek Reaches seem low to me in relationship to the other reaches. I would anticipate that vineyard/agricultural acreage in Dry Creek and Healdsburg Reaches are as high if not higher than the other Reaches and I am concerned that the DEIR is underestimating frost protection needs. e) The report by Davids Engineering, Inc. (March 2013) included in Appendix G to the DEIR provides a detailed discussion on the methods used to derive applied agricultural water estimates. However, the report does not present the numerical results of this analysis beyond estimating the total annual applied water from study years 2002 to The only reported values provided are in Table 2.13 (page 2-21) of the Davids report, which indicates the total annual applied agricultural water volumes ranged from 10,000 to 25,000 AF. There is no presentation on the seasonal distribution of applied water, how it varies by water year-type or what values are utilized in the ResSim model. Because I was not been able to locate the agricultural applied water data in the ResSim model, I contacted SCWA with this question, and received the response from Water Agency Staff ( text and attached loss explanation file) contained in Attachment B. The loss explanation file contained in the Water Agency response lists the ResSim data file names and file parts that are reported to contain the agricultural demand estimates indicated as the focus of my inquiry. However, analysis of the flow data contained in the Hopland, Cloverdale, Healdsburg and Dry 7

8 Creek time series files appear to include only the water budget and frost protection losses discussed in the preceding section d) above. I determined this by comparing the total monthly dry and wet year water losses calculated from the ResSim model data files (see Table 1 below) to the corresponding figures of monthly river-reach loss volumes for dry and wet years (see Figures 10 through Figure 14 from Grinnell s 2016 Streamflow Depletion report contained in Appendix G of the DEIR and presented in Attachment C). The only difference between the monthly water loss volumes in Table 1 and the graphic values in Attachment C is that the March through May volumes in Table 1 include variable amounts of frost water application; no frost water estimates are included in the graphs in Attachment C. Apart for the months of March through May, the values presented in Table 1 match the values plotted on the graphs in Attachment C. Because the graphs in Attachment C only reflect the unaccounted for stream flow depletions, the calculated water loss volumes presented on Table 1 only reflect the same stream flow depletions and don t include applied agriculture or municipal/industrial water demands. TABLE 1: Calculated monthly water loss volumes (AF) from ResSim Baseline Conditions model. Note that frost water applications are included in monthly water loss for March through May only. Calpella Reach Hopland Reach Cloverdale Reach Healdsburg Reach Dry Creek Reach Dry Yr Wet Yr Dry Yr Wet Yr Dry Yr Wet Yr Dry Yr Wet Yr Dry Yr Wet Yr JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC The DEIR report and appendices do not present applied agriculture water demands to the same level of detail as other water budget and model variables. Based on the my review of the ResSim model and information the Water Agency supplied about the location of agriculture water demands in the model, I have not been able to identify if or where agriculture water demands are integrated into the Upper River reach portion of the model. Thus, unless it can be demonstrated otherwise, I feel the DEIR analysis of project alternatives and potential impacts should be considered incomplete, until agriculture demands are clearly and fully included in alternative assessments. 8

9 5.0 Frost Protection and Heat Suppression The ResSim model accounts for frost protection demands, but I was not able to identify any clear water demands attributable for heat suppression in the ResSim model 4. Heat suppression demands are not quantified or described in detail in the DEIR. Therefore, the DEIR should be considered incomplete until the public can identify the demand volumes and how they are incorporated into Project operations. 6.0 Fisheries a) A stated Project objective is to improve sunfish habitat. Is this objective in the Biological Opinion? Having worked on numerous fishery habitat enhancement project, I am concerned about conflicts associated with habitat improvements for both warm and cold water species. Have these competing interests been evaluated in the DEIR? If not, the DEIR should be considered incomplete. b) The DEIR contains no discussion of benefits/impacts to Eel River fisheries. Are we to assume that there are no adverse impacts on Eel River fisheries from continued PVP diversions? What about impacts associated with increased Eel River flows associated with the No Eel River diversion alternative completed as part of cumulative impacts assessment? The DEIR does not address these issues and should be considered incomplete. 4 Correspondence with SCWA staff (see Attachment B) indicates that heat suppression losses from the system are included for in the streamflow depletions estimated by Grinnell and described in Section , Appendix G to the DEIR. 9

10 ATTACHMENT A

11 ATTACHMENT A CALPELA REACH HOPLAND REACH Baseline Flow (AF) Water Budget Loss (AF) Frost Water (AF) Baseline Flow (AF) Water Budget Loss (AF) Frost Water (AF) Min Avg Max Min Avg Max Min Avg Max Min Avg Max Min Avg Max Min Avg Max JAN 1,767 30, , JAN 3,646 97, , FEB 1,297 28,248 96, FEB 2,938 93, , MAR 1,620 17,751 81, MAR 4,191 52, , APR 1,719 9,784 33, APR 2,680 25, , MAY 1,277 7,717 15, , MAY 2,862 13,756 32, ,002 1, JUN 511 6,184 8,817 1,419 1,550 1,617 JUN 3,801 10,677 14,694 1,460 1,570 1,626 JUL 62 5,526 6,391 1,914 2,090 2,438 JUL 3,225 11,659 14,438 2,466 2,473 2,476 AUG 0 5,628 7,222 1,975 2,042 2,174 AUG 16 12,377 14,981 2,538 2,587 2,684 SEP 0 5,469 10,300 1,565 1,575 1,595 SEP ,288 12,919 2,011 2,166 2,245 OCT 0 5,925 16, ,004 OCT 71 10,412 25,463 1,334 1,565 2,021 NOV 2,729 9,655 43, NOV 5,653 18, , DEC 1,809 22,132 79, DEC 5,841 60, , TTLS 154,340 8, % % TTLS 418,713 13, % % CLOVERDALE REACH HEALDSBURG REACH Baseline Flow (AF) Water Budget Loss (AF) Frost Water (AF) Baseline Flow (AF) Water Budget Loss (AF) Frost Water (AF) Min Avg Max Min Avg Max Min Avg Max Min Avg Max Min Avg Max Min Avg Max JAN 5, , , JAN 6, ,923 1,044, FEB 3, , , FEB 5, , , MAR 6,181 81, , MAR 8, , , APR 3,217 38, , APR 4,522 65, , MAY 2,876 16,740 49, MAY 2,951 23,090 92, JUN 3,308 11,051 18, JUN 2,718 12,269 29, JUL 3,000 11,364 13, JUL 2,142 10,545 14, ,204 1,515 AUG 0 11,787 14, AUG 0 10,397 12, ,529 1,877 SEP 0 10,823 12, SEP 0 9,067 13,444 1,358 2,022 2,360 OCT 0 10,812 44, OCT 0 10,877 90, ,070 1,224 NOV 5,822 25, , NOV 5,653 37, , DEC 6,318 87, , DEC 6, , , TTLS 579,406 3, % % TTLS 905,093 8, % % DRY CREEK REACH Baseline Flow (AF) Water Budget Loss (AF) Frost Water (AF) Min Avg Max Min Avg Max Min Avg Max JAN 5,411 66, , FEB 5,051 71, , MAR 5,582 49, , APR 4,644 22, , ,919 Total Avg. Losses (AF) MAY 5,187 9,031 33, JUN 4,954 6,152 10, JUL 5,718 6,501 10, AUG 5,718 6,745 11, SEP 5,534 6,455 10, OCT 4,836 6,664 19, NOV 5,250 11,096 65, DEC 5,411 35, ,

12 ATTACHMENT B

13 From: To: Cc: Subject: Date: Attachments: Jessica Martini Lamb Greg Kamman Jay Jasperse RE: Questions regarding the HEC ResSim model for Russian River Flow DEIR Friday, February 17, :49:33 AM LossExplanation.pdf Dear Greg, Section of the report Russian River Hydrologic Modeling for the Fish Habitat Flows and Water Rights Project (included in the Draft EIR, Appendix G, Modeling Reports), explains the development of agricultural applied water estimates. This is described further in the report Russian River Applied Water Estimates Development Report prepared by Davids Engineering (also included in Appendix G to the Draft EIR). Section describes other system losses, including those from natural processes or not accounted for in metered direct diversions and estimated agricultural diversions, which would account for heat suppression flows. These other system losses are described in a reach depletion report prepared by Stephen Grinnell titled Sonoma County Water Agency Russian River Operations Model: Streamflow Depletion Time Series Development (included in Appendix G to the Draft EIR). Water Agency staff have prepared the attached file to clarify where these data sets are located in the model files provided to Friends of the Eel River. The attached loss explanation shows an example for the Baseline condition model files and is similar for the remaining model scenario runs. If you have further questions regarding the location of these data in the model run files, please contact Don Seymour, Water Agency Principal Engineer, at Donald.seymour@scwa.ca.gov Thank you, Jessica Martini-Lamb Environmental Resources Manager Sonoma County Water Agency 404 Aviation Blvd. Santa Rosa, CA fax From: Greg Kamman [greg@khe-inc.com] Sent: Thursday, February 09, :17 PM To: Jay Jasperse; Jessica Martini Lamb Subject: Questions regarding the HEC ResSim model for Russian River Flow DEIR Jay and Jessica, I am a consulting hydrologist assisting Friends of the Eel River with review of the Russian River Flow DEIR. I have obtained and reviewed the DEIR and ResSim model run input/output files. During this review, I have not been able to identify the Agricultural Applied Water Estimate data sets in the ResSim model. Can you tell me where these data are located in model input or output files? Also, do you know if any heat suppression flows are integrated into the model simulations? Please feel free to contact me with any questions. Thank you,

14 Greg Greg Kamman, Principal Hydrologist 7 Mt. Lassen Drive, Suite B-250 San Rafael, CA Phone: (415) Fax: (415)

15 Input system losses for the model defined below Loss Types Included and Report Section for Description Model Location DSS File Time Series in DSS Appendix G: Russian River Hydrologic Modeling for the Fish Habitat Flows and Water Rights Project Section Section Section Section Part A Part B Part C Part D Part E Part F Municipal and Industrial Demands Agricultural Demands Water Balance Losses Frost Protection Redwood Valley Div RR System Losses POR to v dss REDWOOD VALLEY FLOW 01JAN JAN2013 1DAY UPPER RR YES NO NO NO Coyote Basin Div RR System Losses POR to v dss CALPELLA FLOW 01JAN JAN2013 1DAY UPPER RR NO NO YES YES SCWA Div RR System Losses POR to v dss SCWA DIVERSIONS FLOW 01JAN JAN2013 1DAY LOWER RR YES NO NO NO Healdsburg Fitch Div RR System Losses POR to v dss HLDSBRG FITCH MTN WELLS FLOW 01JAN JAN2013 1DAY LOWER RR YES NO NO NO Windsor Div RR System Losses POR to v dss CITY OF WINDSOR FLOW 01JAN JAN2013 1DAY LOWER RR YES NO NO NO Lower River Ag Div RR System Losses POR to v dss HACIENDA AGG FLOW 01JAN JAN2013 1DAY LOWER RR NO YES NO NO Cloverdale Div RR System Losses POR to v dss CLOVERDALE FLOW 01JAN JAN2013 1DAY UPPER RR YES YES YES YES Healdsburg Div RR System Losses POR to v dss HEALDSBURG FLOW 01JAN JAN2013 1DAY UPPER RR YES YES YES YES Dry Creek Div RR System Losses POR to v dss DRY CREEK FLOW 01JAN JAN2013 1DAY DRY CREEEK NO YES YES YES Healdsburg Dry Creek Div RR System Losses POR to v dss HLDSBRG DRY CRK WELLS FLOW 01JAN JAN2013 1DAY LOWER RR YES NO NO NO Hopland Div RR System Losses POR to v dss HOPLAND FLOW 01JAN JAN2013 1DAY UPPER RR YES YES YES YES RRCWD Div RR System Losses POR to v dss RR COUNTY WD FLOW 01JAN JAN2013 1DAY LOWER RR YES NO NO NO

16 ATTACHEMENT C (from: Grinnell, S., 2016, Sonoma County Water Agency Russian River Operations Model: Streamflow Depletion Time Series Development contained in Appendix G of DEIR.

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