|
Action on Final Environmental
Impact Report (FEIR)
Water Supply and Transmission System Project (WSTSP) October, 1998 The Final EIR for the WSTSP was released on October 14, 1998 when release notices were mailed on where to find the FEIR and where to buy a copy. On the October 13, 1998 Board of Supervisors/Directors meeting Consent Calendar, it included the action item to hold a hearing on the FEIR on November 2, 1998. A 2.5 week notice was protested by members of the public as being inadequate notification to review another 4 volume release. The review period for the original 8 volume release was for 85 days. The Board responded by setting Friday, November 13 (5pm) as the deadline for written comments on SCWA's transmission system expansion Final EIR. The released FEIR volumes were Volume I, VI, VII, and VIII. DEIR Volumes II, III, IV, V, and VII are assumed to still be part of the FEIR. Text in the FEIR that comprised modifications and responses to comments were in bold type. However, all changes were not in bold type. The purpose of the WSTSP is to serve 350,000 people in Sonoma and Northern Marin County and 170,000 in the Marin Municipal Water District (MMWD) and to meet the projected needs for additional water use by contractors based on area General Plans. (Refer to Table 3-C for the daily entitlements of each water contractor.) Of the 8 main contractors, five maintain some local sources of supply in addition to the water purchased from the SCWA. The water contractors, with the exception of Forestville Water District, requested that the 1974 Agreement be revised to authorize the financing and construction of additional water supply and transmission facilities for future water demands. The current Agency water permits allow no more than 180 cubic feet per second (116.3 MGD) and 75,000 AFY. Current delivery obligations, under existing contracts, are for 92.0 MG which is approximately 142 cfs, below the 180 cfs limit. Million gallons per day or MGD is used to explain the average peak monthly delivery entitlement for water contractors and transmission customers and is based on the capacity of the transmission system, or the highest rate at which water can be moved through the transmission system. Acre feet per year or AFY is used to explain the annual delivery limits for water contractors and the maximum amount of water that the SCWA is authorized to store, divert, re-divert under water right permits. (Pg. 4-5) Direct diversion refers to water diverted directly from stream flows. Re-diversion refers to water that has first been diverted to storage in a reservoir, then later released and re-diverted at a point downstream. Increased diversion of water from the Russian River will be offset by increased releases from Lake Sonoma or will occur during a time of year when unappropriated water is available, as determined by the State Water Resources Control Board. The project goals are:
Environmentally Superior Alternative: Because the ASR Component was deleted from the proposed project, the SCWA determined that the Combined-Component Water Supply Alternative C-1, the environmentally superior alternative, would now best meet the project objective. In the DEIR, the preferred alternative was Alternative A-1. (The No Project Alternative would still be environmentally superior, however, CEQA allows the selection of an environmentally superior alternative from proposed projects.) The No Project Alternative is now defined as the conditions prevailing at the maximum level currently authorized by Decision 1610 and all components of the Russian River-Cotati Intertie project, including Collector No. 6. (Pg. 7-17) The project components are:
The Increased Use of the Russian River Project or "Russian River Component" will be releases of water from Lake Sonoma to meet the project demands. The Lake Mendocino releases will be used to meet the minimum stream flows set by SWRCB in Decision 1610 in 1986. The Lake Sonoma water would run down Dry Creek and be either extracted at the Mirabel/Wohler well sites or be taken out at other diversion points, to be identified in the future. The Transmission system expansion or "Transmission System Component" will be diversion, water production and treatment facilities, plus distribution facilities with pipelines, storage tanks and booster pump stations. Diversion facilities such as Ranney-type collector wells, conventional wells, infiltration ponds, diversion structures, water treatment facilities, pumps, connecting pipelines, and appurtenances would be constructed and, except for proposed Collector No. 6, will be the subject of a subsequent environmental impact report. (Pg 4-19) MMWD & Transmission System Capacity: The SCWA and the Marin Municipal Water District (MMWD) have two water supply agreements, recently amended on January 25, 1996. The MMWD is now entitled to delivery of 14, 300 AFY, but the Agency's obligation is dependent on delivery or transmission system capacity. MMWD now is obliged to help SCWA meet the cost of the Warm Springs Dam, share the cost of Agency efforts to continue the PG&E Potter Valley Project or to acquire it, and pay for the delivery of water. The first supply agreement is for 4,300 AFY limited to 3.8 MGD from May-September and 8.0 MGD from October-April, the "off-peak" period. The second supply agreement is for 10,000 AFY limited to 9.0 MGD from May-October but "higher" other months. Delivery is through the Petaluma Aqueduct. In order for MMWD to receive water, these conditions must exist:
The SCWA is obligated to release up to 9,300 AFY from storage and MMWD has a right to purchase an additional 5,000 AFY. MMWD's right to transmission system capacity is subordinate to the rights of the eight original water contractors. The WSTSP will expand the transmission system to provide for MMWD's water, however the right is still subordinate. 20 MGD Standby Water: In 1991, the SCWA Board of Directors approved the "Wohler Aquifer Acquisition and Capacity Restoration Project" or Capacity Restoration Project for two purposes; 1) acquire the property upstream from the Wohler collectors to protect the Wohler aquifer and 2) construct three conventional wells to restore production capacity of the Wohler collectors which had declined from 32 MGD to 23 &endash; 25 MGD, depending upon the infiltration rate of the two Wohler ponds. The three wells to date have not been constructed. In 1993 (1994), the SCWA Board of Directors approved the "Russian River Well Field (RRWF) Development Project" to provide 20 MGD of standby water. The project, completed in 1997, consists of 7 conventional wells withdrawing water on Agency property in the Mirabel area. The wells were expected to produce 20 MGD but "capacity has proved to be substantially less." The wells are ringed closely around Collector No. 5. The SCWA changed the purpose of the Well Field to now "accomplish the purpose of the Wohler Aquifer Acquisition and Capacity Restoration Project". Connections from the wells are now into the Santa Rosa Aqueduct and the Russian River-Cotati Intertie. The wells have been used to restore the production capacity at Wohler to the original 32 MGD and the total Wohler and Mirabel capacity back up to 92 MGD. (pg. 3-16 & 3-17, 4-6) Now the SCWA needs to find another way to meet the 20 MGD standby. Collector No. 6: Collector No. 6 would be used to produce 16 to 22 MGD utilizing natural infiltration (no additional pond is needed for increased infiltration.) Collector No. 6 would provide the "20 MGD of standby water supply capacity, add operational flexibility to the water transmission system, and meet the Agency's obligations under the 1974 Agreement for Water supply to reliably deliver water at a maximum monthly average rate of 92 MGD." (Pg. 4-8) . The July 29, 1974 EIR planned for 3-4 Ranney-type water collectors at Mirabel. Collector No. 6 would consist of the construction, maintenance and operation of a Ranney collector well, connecting pipeline and appurtenances. It would be located approximately 2,400 feet upstream from the existing Collectors No. 1 and No. 2 at the Wohler site and approximately 450 feet from the Russian River. The caisson would be 30 feet above ground level. The pump house would sit about 30 feet high, as would the berm around the pump house. It is not expected to be visible from most public viewpoints. Appurtenances would consist of access roads, electrical facilities, observation wells, 30 foot high radio telemetry equipment and water treatment or disinfection equipment. Four to seven observation wells will be used to monitor water levels. Ground water levels in the vicinity of Collector No. 6 would be lowered and would affect the amount of water available in neighboring wells. The effect would be between 2 to 12 feet of lowering. Private wells within 1,000 feet of Collector No. 6 will be monitored for one year. (Pg. 5.3-25) Monitoring could be extended should the SCWA determine that it is needed. The Wohler site would include the construction of the berm out of approximately a 1.5 foot layer of soil excavated from 12 acres. This would create a broad, shallow depression in the flood terrace of the Russian River. Riparian habitat would be removed. The collector would be 3,000 feet from the Benoist Pit. The Benoist Pit is approximately 3,000 feet across and directly next to the Wilson pit. The Wilson pit is approximately 2,000 feet wide and borders the 20 acre Kaiser Sand and Gravel plant. Potentially, if all pits in the area blew out from flood water pit capture, a likely path for the River will be across the jutting meander, which will house the future Collector No. 6, cutting the meander off as an island. During the DEIR comment period, there was considerable outcry against location of Collectors No. 7 & 8 on productive agricultural land. Requests were made, and put into place by the Board of Directors, to study the use of Kaiser Sand and Gravel as a potential extraction site. Figure 7-8 shows alternative locations for Collector No. 6, still showing the agricultural lands, the Kaiser site, the Anderson property below Wohler Bridge, and a new site south of the Mirabel area. The FEIR dismisses the Kaiser site because of "connection costs", however there was no documentation showing the costs in the FEIR. The use of Kaiser property was summarily dismissed in the FEIR with a statement that the site was "not financially feasible" due to pipe distance costs, however, they never provided any documentation that proved the point. With deep digging in the document, the only facts uncovered was a general statement that pipe would be costed out at $8.00 per developed foot, but no reference was ever made to the distance to be covered, nor a concluding cost, thus no determination of reasoning for eliminating the option. It is interesting to note in the Response to Comments section, the response to the letter by the Department of Health Services states "the Agency recognizes that removing gravel make a site unsuitable for a conventional well or collector." The Anderson property, located south of the Wohler Bridge, is also eliminated based on the draw down against the SCWA's own wells and reliance on the current rubber dam. The Mirabel area site was rejected due to drawdown against the SCWA's own wells and reliance on the current rubber dam. Both were dismissed due to the inability to produce 20 MGD. The new site south of the Mirabel area was not studied in the Biological assessment. It appears that selection of Collector No. 6 site on the north edge of the current Wohler site was due to the fact that the SCWA already owns the land and would be a close connection point. However, the same could be said for the "Mirabel-South" and the Anderson site. It will remain to be seen, after repeated failures of predicted production rates, whether the selected site will produce 20 MGD. The alternate locations noted in the FEIR will become "potential feasible locations for water production facilities and will be analyzed in a subsequent environmental report that analyzes diversion alternatives for the WSTSP." (Pg 7-32) Aquifer Storage and Recovery (ASR): The ASR continues to be discussed as a water supply alternative and no longer as a stand-by emergency water component. The ASR program would be for water diversion from the Russian River of 55 MGD when flows exceed 125 cfs during the time from November to May. ASR wells would be approximately 65. Tests for ASR were carried out in the Santa Rosa and the Sonoma Plains. Other Diversion Points: In addition to diversion points identified in the original DEIR, four other alternative locations with seven types of facilities were reviewed. The types and locations of future diversions will be identified in the future and will have a project-level EIR. An example of future diversion points is shown in Figure 4-C pg 4-7, which shows a diversion area from the Warm Springs Dam covering the entire Dry Creek watershed, and down the Russian River as far as Guerneville. Reference is made to Diversion Facilities being discussed at the program-level and the reader is referred to Appendix T (which contains only general statements of future decisions.) In Response to Comments, it was noted that the area's agricultural property may again be considered in the future for diversion alternatives. (Pg 190.) Chapter 4 discusses the possible diversion facilities. The facilities would be located in an area where it would be possible to achieve production capacity of "57 MGD". The options are:
Table 1B in Volume VII Appendix H shows the Capital Program Cost Allocation for High Water Use Projection. This assumes three Water Supply Facilities of 19 MGD each, to be built in 2000, 2006, and 2013. There is no cost estimate for conventional wells or a treatment plant. Pipelines:
Pipeline construction will be underground installation of approximately 241,000 feet of 18 to 60 inch diameter steel pipe. Actual pipeline alignments will be determined in the future, however, proposed approximate locations are shown in a number of graphics in the FEIR. Pipelines being built parallel to current pipelines appear to be for the purpose of differentiating transmission capacity and delivery between the contractors. The new pipelines crisscross the older pipelines both in the south and the east county areas, sometimes using the same booster stations, whether old or proposed. It certainly couldn't serve the purpose of avoiding the same earthquake faultlines as they run fairly closely to older pipelines. Tanks: Three to five steel tanks would be constructed. Only one tank, the Kawana Springs Tank No.2 for 10 MG is described in project-level detail. The other locations will be determined and will be "described in future environmental documents in project detail". The names of the pending tanks are: 1) Cotati Tank(s) for 33.5 MG and 2) Kastania Tank No. 2 for 12 MG. Booster Pump Stations: Masonry buildings surrounding the pumps would be 35 feet wide by 45 feet long and 15 feet high. Antennas would be 20 feet high masts. Proposed stations are 1) Cotati-Kastania and 2) Sonoma modification (pumps 2 and 3). Energy Impacts: Increased Lake Sonoma Discharge Impacts: Lake levels would be expected to fluctuation 40 feet 3% of the time and could range from 427 feet to 336 feet mean sea level (MSL). Recreational impacts would mean that at 320 feet MSL lowest lake level, the public boat ramp would be unusable. Total sediment discharge data for Dry Creek for the mid-1980's was reviewed by the SCWA to evaluate the effect of the proposed increase in releases from Lake Sonoma. High sediment occurs during high water, winter flows, and no substantial increase is expected in dry weather flows. Water levels and velocity are not expected to have a significant impact due to the flow rate and width of the river. The area inundated would change only a few tenths of a foot and therefore ground water recharge along either Dry Creek or the Russian River is not expected to change. Current daytime temperature of the Russian River below the Dry Creek confluence during summer is 71.6 degrees. The larger volume of water is expected to result in a temperature of 68 degrees. The SCWA did not respond to a comment on the DEIR asking what the cumulative impacts would be from increased growth and reliance on water in Sonoma and Marin County in conjunction with the drawdown of the Lake and the stipulation for reduced withdrawals of 30% in critically dry years. In critically dry years, under Decision 1610, SCWA must curtail it's releases from Lake Sonoma by 30%. In other words, more people brought in by more development will be relying on less stable water. Fisheries Impacts: Impacts were anticipated from changes in water temperatures in Lake Sonoma, changing flows in Dry Creek downstream of the Lake, Russian River flow changes below Mirabel, and removal of riparian vegetation with potential erosion and increased sedimentation. Levels in Lake Sonoma would drop sooner and lower in the year. The project, in combination with related projects, is expected to result in significantly higher flows for the dry season in Dry Creek and in the Russian River under normal, dry and critically dry water supply conditions compared to pristine conditions. The project in combination with related projects would effect fisheries by changing the hydrology of the River with altered stream flows and blocked passages, increased turbidity, and the decrease of water for dilution of pollutants downstream. Losses may be less-than-significant for individual projects but the combined, cumulative effect is significant and unavoidable. Water temperature changes due to releases from Lake Sonoma are not expected to alter Dry Creek conditions except during critically dry years. In normal years, the water was expected to be cooled a few degrees, thus was considered beneficial to the fish. Rainbow trout migrate out of Lake Sonoma into the tributaries above the lake during spawning season. It is anticipated that during critical spawning months the Lake height or reservoir levels would not impede fish passage. Minimum water temperatures in Lake Sonoma for trout in critically dry years could be exceeded approximately 3% of the time resulting in death. (normal exists approximately 86% of the time, dry 11% and critically dry 3%.) Temperature also effects the dissolved oxygen and poll stratification. Outlets at different heights in the dam would allow for releases that could be altered to change the temperature modeling to conserve the cold water pool in Lake Sonoma and the impact is considered less than significant. The FEIR included a new section on Public Trust, which addresses the protection of navigable waterways and the fish, navigation and recreational uses by the public. Public Trust lands have not been defined in the project area, though the State Lands Commission is "in the process of determining the State's rights in the project area." Once State ownership is determined, the SCWA will apply for permits under Public Resources Code Sections 6223, 6303 and 6327. The cumulative impacts to fisheries and the inability to address Section 7 impacts, especially with the biological impacts study still pending raise significant questions and concerns with the FEIR. Deletions from the Project: The following were deleted:
The Kawana Springs project was approved July 22, 1997 by the Board of Directors in Resolution 97-0994. The project was taken out of the long term EIR and "Site-specific analysis was performed and a Notice of Exemption was approved by the Board of Directors." (pg 3-36) The reason was "to expedite the development and environmental review to meet existing demand." In Section 5.1, is reference to the fact that the ASR component was deleted from the preferred project and is "no longer analyzed for project impacts." However, the "ASR is still analyzed as a water supply alternative." ( Pg 5.1-1) (Volume VIII on Response to Comments repeatedly stated the ASR was removed and therefore no response to comments was necessary.) Collectors No. 7 & 8 were located on agricultural land on the opposite side of the river from Wohler, across from to the Benoist and Wilson Pits. (Collector No. 9 in the DEIR is in the 1,000 yard area on the Anderson property immediately below the Wohler Bridge now slated as a rejected alternative site for Collector No. 6.) Program Level and Project Level Impacts: The 2.3 Summary of Environmental Impacts states that the EIR is both a program level impact for water supply over an extended period of time and project level for constructing water supply and transmission system facilities. (Pg.2-7) The 3.10 Events and Actions section notes that the Collector No. 6 is now included at a project-level and that all other diversions are kept in at a program-level. (Pg 3-35, 4-8) The 4.10 Project Approvals section states that several aspects of the WSTSP have been described at the "project-level" and will not need future environmental review. They are:
Collector No. 6 was originally supposed to address future water needs but is now proposed to meet current water needs. The site-specific impacts of the collector were included in the DEIR. Program level impacts were supposedly met in an earlier 1974 document. The General Manager has been given the authority to write a separate EIR for Collector No. 6 if there is a delay in the FEIR certification. (Pg 3-37) The 4.10 Project Approvals section also states that future project level environmental reviews will be needed. They are:
The Kawana Springs Tank No. 2 facilities and impacts are analyzed in project-level or site-specific detail in the FEIR. (Pg. 4-21) (See reference above in the Deletions section.) The Kawana Springs Pipeline/Station extension via the West Santa Rosa-Ralphine Pipeline is still necessary and included at the program-level. The Right-of-way property acquisition for transmission system facilities for the WSTSP will be described in future environmental documents in project level detail. (Pg.4-33) Pipelines and power lines will need 50-foot wide easements across private property. The Cotati and Kastania tanks will need 3 to 15 acres of land and would need to be acquired in fee. The actual site will be determined in a subsequent environmental document at project level detail. The Cotati-Kastania Booster pump station will need one acre of land and will be determined in a subsequent environmental document at project level detail. FEIR Planning Period: The planning period for the WSTSP is stated to cover 1995-2015. Increased water capacity needs were based on general plans with shorter time horizons that 2015, ending anywhere from 2000 to 2010. In the areas with shorter time frames, growth was assumed to stop at the general plan end dates. (pg.4-9) In Response to Comments # 54-37, the SCWA states "The WSTSP is not a plan to provide water through the year 2015. The WSTSP is a plan for providing water to meet the projected demands of all of the general plans within the Agency's service area… The Agency is not proposing a plan for regional water demands beyond the scope of the current general plans of the area." Table 4-A shows the results of the demand estimates based on a formula taking the general plan projections, historical water use, weather data, growth projections for population, employment and commercial space, and reduction by conservation savings. Marin's use is approximately 22% of the expected 149.0 MGD monthly delivery limit. North Marin would receive 15,300 AFY to serve a population of 83,600 by year 2015 (cost of 9.85% of Project). Marin Municipal Water District would receive 14,300 AFY to serve a population of 174,149 by the year 2005. Table 4-A outlines the annual and monthly delivery limits to be used under the "Proposed Water Agreement" for all water contractors. Construction Schedule: The construction period will occur during the months of April through October. The WSTSP facilities are expected to be constructed between 1998-2018 starting with the construction of Collector No. 6 in 1998 and ending with the construction of the Cotati Tank(s) in 2018. Costs: The Collector No. 6 cost of $8.5 million and the Wohler-Forestville Pipeline cost of $3.7 million will be funded through revenue bond proceeds and income from water sales and are funded as "remaining facilities" under the 1974 Agreement for Water Supply and their costs are NOT included in the cost estimation of the WSTSP. The total cost of the WSTSP is $144 million. The financing will be through cash reserves, bond financing or other debt financing. It will be necessary to generate approximately $6.5 million per year of additional operating revenue in excess of operating expenses through the year 2020. The maximum rate projection for Santa Rosa Aqueduct water would be $308 per acre-foot (Santa Rosa). The Petaluma Aqueduct rate would be $373 per acre-foot (North Marin, Rohnert Park, Cotati, Petaluma). Forestville Aqueduct would be less than the current $301 per acre-foot. Sonoma Aqueduct will be $487 per acre-foot (Sonoma and Valley of the Moon). New Water Agreement: A new Agreement for Water Supply would be needed to authorize the development of additional water supply and the expansion and revised operation of the transmission system. The "Proposed Water Agreement" would provide for the financing, design, construction, operation, and maintenance of water supply and expanded transmission system facilities necessary to meet peak month deliveries at an average of 149 MGD. (pg. 4-15) 149 MGD was derived from summing of all the monthly delivery requests by the SCWA customers. This is an increase of 57 MGD. The "Proposed Water Agreement" would limit the annual delivery obligation to each of the water contractors seeking an increase in water supply to amounts necessary to meet the demands outlined in General Plans in the service areas. (Under the 1974 Agreement, there are no annual delivery limits.) Table 8 in Volume VII Appendix H, titled "Proposed Agreement for Water Supply Delivery Entitlements" outlines 145.1 MGD and 73,620 AFY for all customers. Table A2 "Annual Water Delivery Projections in Acre-Feet &endash; Low Water Use Projection" shows total water deliveries to all customers of 83,952 AFY by 2020. Table B2 shows high water use projection of 93,343 AFY by 2020. Figure Q1 in Volume VII Appendix Q shows Production as 148.9 MGD with 20 MGD spare with Collector No. 6 and Proposed Delivery Entitlements of 148.9 MGD to 8 contractors plus MMWD and others. Permit applications will be asking for 230 cfs and 101,000 AFY. 148.9 MGD is approximately 223 cfs. The "Proposed Water Agreement" includes a provision that would allow a contractor to modify its annual delivery limit for the purpose of conforming to a general plan update. The provision would not result in a change in average monthly delivery limit. Approval of the modification would be subject to approval of the SCWA and the contractor separately from approval of the FEIR. The "Proposed Water Agreement" will fund a study to develop an off-stream source of emergency and standby water to provide approximately 30% of the future proposed demands. An additional off-stream water supply (beyond the current three existing emergency wells) will be created in the future and will be part of a future environmental assessment. The new agreement would not obligate the SCWA to build the offstream facility. The proposal to provide an off-stream emergency supply is not part of the WSTSP. (Pg. 4-16) General Plans: Section 6.2.3 addresses the General Plans in the WSTSP service area. Three of the general plans in the area have been updated since the DEIR was written. Information from the updated plans has been included but the WSTSP is not proposed to change as a result of the updated general plans. By the end of the 2015 study period only two General Plans, for Sonoma and North Marin, still applied. General Plans and population projections were utilized to develop a water production projection model. However, in comments on the DEIR it was pointed out that projections showed a 155 gallon per person per day usage in 1995 and a 90 gallon per person per day usage in 2010. Normal per capita experience is 50 gallons per day. The SCWA response stated that per capita usage was not used and water demand projections were made based on historical water usage data. Potter Valley Project: The Federal Energy Regulatory Commission (FERC) is preparing an Environmental Impact Statement (EIS) under the National Environmental Policy Act (NEPA). The EIS will analyze three alternative flow proposals and a no project alternative. The result should be a decision by FERC on future modifications of flow schedules and structures to protect and maintain fisheries resources in the Eel and East Fork Russian Rivers. The DEIS is expected to be released in last 1998. The FERC process could entail a 20% decrease in flow of water to the Russian with the final decision to restore water into the Eel River to recuperate depleted fisheries. The PVP is discussed in the FEIR 6.3 Chapter on Cumulative Impacts, and the conclusion on pg 6.3-4 is "The impacts of the PVP on the WSTSP, therefore, have been analyzed based upon existing conditions." In Response to Comments, #2-1, the SCWA states that "No changes in the Russian River above Healdsburg would occur as a result of the WSTSP; therefore there would be no cumulative impacts to the Eel River system as a result of the WSTSP." (Italics added.) In addition, the FEIR notes on pg 6.3.5 that the combination of the proposed WSTSP and other proposed diversions would increase total diversions from the Russian River watershed by approximately 66,500 to 69,500 AFY raising the total to 173,500 to 184,500 AFY. However, the conclusion was the State Water Resources Control Board (SWRCB) would require additional EIRs for disputed permit applications (leaving one with the impression of piecemealing of the process and no real answer to the overall or cumulative impacts.) The SWRCB in assessing new water rights permits can modify terms relating to Public Trust Resources. (Pg. 6.3-6) New Water Right Permits: Current permits allow storage of 122,500 AFY in Lake Mendocino and diversions/re-diversions at Wohler/Mirabel of 92 cubic feet per second and 37, 544 AFY and the storage of 245,000 AFY in Lake Sonoma and direct diversion at Wohler/Mirabel of 180 cfs. Combined diversion/re-diversion under the Agency's four permits allows 180 cfs or 75,000 AFY. New permit applications by the SCWA would petition the SWRCB/DWR for additional Wohler/Mirabel direct diversion of up to 230 cfs and the new combined limits of 230 cfs and 101,000 AFY on all direct diversion and re-diversions. (Appendix G) Petition for Changes for WSTSP would be a combined rate of direct diversion and re-diversions at Wohler/Mirabel to include the new water right permit described above with the current permits for a total of 230 cfs and 101,000 AFY, and to add Collector No. 6 to be an authorized point of diversion and re-diversion under the existing water right permits. |