On April 30, 1998, a Thursday, the SCWA sent a Public Meeting notice to 800 entities, of a hearing on May 5th, a Tuesday, that the Board of Directors would be recommending modifications to the WSTSP. Public members protested the short notice and the Board continued the hearing to May 19, 1998. 

On May 14, 1998, SCWA staff began to recondition the three Emergency wells on the Santa Rosa Plain. The public thought that this project was part of the DEIR, beginning before the certification process, however it was just a reconditioning of two of the current wells. The wells were dug to 800 to 1000 feet but there was a collapsing of sand into the well shortly after development, resulting in decreased usage. The wells were designed for total production capacity of 7 mgd but were averaging 5.2 mgd. Improvements included one pilot hole/observation well, four observation wells and one production well. The result was a replacement of two wells and abandonment of the original wells. 

On May 19, 1998, the Board of Directors of the SCWA directed the General Manager to prepare a separate EIR for Ranney Collector 6 under "specified circumstances". This was action in response to staff asking that the 1996 pending FEIR for increased water appropriation and expanded transmission system be altered. The reason for the request for a separate EIR for Collector No. 6 was "a Final EIR for the WSTSP would be delayed by several years, and future water delivery curtailments or shortages may occur."

In the project Transmittal Report submitted by Randy Poole, General Manager for the SCWA, to the Board of Directors, he supplied the background for the request. Over the 85-day public review period on the WSTSP draft EIR, approximately 100 agencies, organizations and individuals responded, comprising over 1,000 comments on the project plan. On December 10,1996, the Board directed staff to respond to the comments and complete the final EIR. Due to the scope of the comments and the number of additional diversion alternatives, completion of the FEIR will be delayed, unless it is modified, per the General Manager.

The alterations recommended by the General Manager were:

1. Delete the Aquifer Storage and Recovery (ASR) component from the preferred project.
2. Include analysis of diversion alternatives at a program level, rather than project level.
3. Identify Collector No. 6 as a Russian River - Cotati Intertie Project, needed to meet existing demand, and prepare a separate environmental document for Collector No. 6 under specified circumstances.

The ASR was intended to provide 44.5 mgd of production and to be an offstream emergency water supply available in case of a toxic spill in the Russian River. Poole admits that the comments opposing the ASR was extensive and that eliminating it as a component would leave the size and design of the remaining WSTSP facilities, and more importantly, the quantity of water diverted, unmodified.

The ASR information would remain in the FEIR but the component would not be included in the description of the preferred project and no additional research or responses to comments about the ASR would occur.

The plan was to return later to the Board to initiate preparation of an environment document for an emergency offstream water supply project at some time in the future. The question will be whether the State Water Resources Control Board's Division of Water Rights, as Responsible Agency, agrees that this addresses cumulative impacts or whether the FEIR is defensible should a citizen bring suit that cumulative environmental impacts have been dodged.

Based on public comment, four additional alternative locations in combination with seven alternative types of facilities are to be considered, many of which were not considered in the DEIR. The proposal is to include new alternatives, but because of lack of analysis which could take two to three years, the FEIR will only address them at the program level and will begin to prepare a second EIR on site-specific diversion alternatives. Until that second EIR is completed, the SCWA cannot construct new facilities.

Ranney Collector No.6 was first mentioned in the 1996 DEIR. Prior to this, in the May 6, 1991 Negative Declaration for the "Wohler Aquifer Acquisition and Pumping Capacity Restoration - Russian River - Cotati Intertie Project", it was described as three wells. The project as described in the Negative Declaration was to restore the original 32 mgd production of the Wohler Collectors with some additional stand-by capacity, and to acquire permanent rights to lower the gravel bar each spring on the "MacMurray" property. The proposal was to buy the property, now projected to be used for "Collector No.6". The property wasn't included in the 1993 Public Scoping document.

The three wells were not Ranney collectors, but "three 70 to 100 foot deep wells with approximately 40 horsepower submersible pumps on the easterly bank above the Russian River." In fact, the Neg. Dec states "Investigation recommended the use of vertical wells for induced infiltration in the project area, rather than collectors similar to the existing Wohler Collectors. The reasons for this recommendation are that vertical wells can create sufficient lowering, or drawdown, of the aquifer to induce infiltration from the River, and vertical wells are less expensive, easier to maintain, and more flexible to operate." Furthermore, the document preparer finds, "Any pumping facilities must be located far enough away from the existing Wohler Collectors to prevent impairment of their water supply. For this reason, the most southerly portion of the MacMurray property near the existing Wohler Collectors could not be used for any additional pumping facilities (see Existing Facilities Map, Figure 3.)" At the time of the 1991 assessment, the Wohler Collectors (#1 and #2) and the Mirabel Collectors ( #3, #4, and # 5) were allowed under Permits 12949 and 12950 for direct diversion of 20 and 60 cfs respectively.

The General Manager, Randy Poole, reported that SCWA had proceeded with the construction of the Kawana Springs pipeline and Booster pump station. In addition, it had acted on the approved Amendment No. 10 to guarantee water to Marin County (formerly standby water) and to remove water quality as a part of their contract with the eight water brokers who utilize their systems. The Kawana Project and the activities authorized by Amendment No. 10 were included in the WSTSP but were not necessary for future water supply. They will not be included in the FEIR.

Poole went on to indicate that the SCWA had experienced two unexpected water shortage events. Poole raised concerns with the ability of the SCWA to provide 92 million gallons per day. Robert Beach, consultant and former SCWA General Manager, prepared in February and July, 1997 reports on water transmission system reliability and the risk of curtailment. Both reports with Board Notes were included in the republished volumes of the October, 1998 FEIR comprising Appendix R, S and T.

Beach's February/March 1997 (FEIR Appendix R) report addresses an August, 1996 storage decrease of water transmission supply to a total of 40 million gallons or a "12 hour" supply. The decline in water storage was caused, during the week of August 11-17, by the Agency's practice of curtailing pumping during PG&E's on-peak period in order to reduce costs. This was exacerbated by a subsequent PG&E curtailment of power on the 13th. Beach notes that the transmission system had the capacity to meet all current and future water demands

The consultant's conclusion was:

1. modify the pumping schedule and don't try to save on electrical power posts,
2. negotiate with PG&E for "firm" delivery of electricity,
3. pump Russian River Well Field Wells (non-Ranney) 1, 3, 4, 6 and 7 into the Collector No. 1 to restore original planned 32 MGD,
4. move Well No. 10 to Cotati Intertie,
5. construct Kawana springs Tank No. 1 and Booster stations that were discussed in the DEIR and
6. build Collector No. 6.

The conclusion, later, by the General Manager was not to address directly a future electrical failure, but instead to require additional water extraction or "standby water" from Collector No. 6 to make up the necessary "emergency" water. . The report notes that the SCWA three emergency wells should produce 6.0 MGD and are allowed to pump 5 days continuously (or more if permitted) producing 30 MGD.

Beach's July 1997 (FEIR Appendix S) report addresses again the question of water transmission system reliability, this time caused by the Agency's own impacts. During the week of June 12 through June 25, 1997, the agency suffered a decline to 46.7 MGD or about a "12 hour" supply. The decline was attributable to a combination of factors and showed some "serious transmission system deficiencies, some of which have not heretofore been recognized." Starting in May and going through July, infiltration rates in the Mirabel infiltration ponds averaged .10 foot per hour well below the 0.17 foot per hour needed to produce 60 MGD.

The Agency initiated a study of their infiltration problems at Mirabel in early May. The original Mirabel pond system was based upon an infiltration of 50 gallons/sq foot/day or a flow rate of 84 MGD. But the average infiltration rate for ponds 1 through 4 averaged 30 MGD for their combined 38.5 acres. Pond 1 showed little decline over a 7 week period. Pond 2 declined rapidly and was taken out of service. Pond 3 was taken out of service in July and two three-inch layers of sediment was removed rather than the single three-inch layer in other years. Also the removed material was not replaced. The pond performed at a higher infiltration rate. The conclusion was the ponds have been contaminated with silt impairing their infiltration rates.

Beach noted that the pumping and operational facilities of the Mirabel/Wohler sites were damaged in the winter floods and were not replaced quickly enough to sustain pumping capacity. Also, the "replumbed" water should be discharged to a settling pond rather than into the infiltration ponds.

The conclusions were:

1. A comprehensive investigation of the causes of the decline in infiltration rates in the Mirabel ponds was needed,
2. Construct Pond 5 as soon as possible,
3. Get a spare motor to do repairs quickly,
4. Rehabilitate the Santa Rosa Plain emergency wells and restore pumping capacity,
5. The Russian River Well Field (RRWF) ponds should be "re plumped" so they pump waste into the settling pond and not into infiltration ponds,
6. Spare parts for flood damaged equipment should be kept in stock allowing earlier replacement,
7. RRWF: should move the wells from pumping to Wohler to Collector No. 5 and direct to Cotati Intertie,
8. Build Kawana Springs Tank No 1,
9. Build Kawana Springs pipeline and booster pump,
10. Collector No. 6 should be built on the former MacMurray, agency-owned property and given a high priority,
11. Diligently pursue the increase in water appropriations.

In the May 5, 1998 Board Report, General Manager Poole stated that all of Beach's recommendations have been implemented or are underway except the construction of Collector No. 6. Beach's report notes that a program level impact study was done for Collector No. 6 was prepared in 1991, but the project was never constructed and states that a project level environmental study is needed. (Note above that the 1991 study only addressed non-Ranney collector wells.)

An EIR prepared in 1974 for the Russian River-Cotati Intertie Project is approximately 50 pages long. The FEIR discusses Intake Alternatives (pg 3-4) and notes that during a study of a 10 mile radius of the existing Wohler installation, consultants concurred that 'geologically there appears to be a 6,000 foot length of the Russian River starting 1,000 feet downstream of the Wohler bridge that has pervious alluvial deposits in excess of 60 feet deep that would be suitable for the installation of Ranney Collectors." Note, this is NOT the MacMurray property or even the "Anderson" property in the 1998 FEIR.

Destruction of vegetation was the reason for the Wohler Site being dismissed in the 1996 DEIR for a Ranney collector. The 1974 Russian River-Cotati Intertie Project EIR provided a general statement that revegetation would occur. However, the 1974 EIR was written so long ago that it was before mitigation measures were required; therefore there was no mitigation in the 1974 EIR that mandated revegetation.