May 11, 2002

Fellow members of the Russian River Watershed Council:

It has been suggested to you that the Lake Mendocino Fishway concept is fatally flawed.  The basis for this accusation is a letter dated February 28, 2000 from the Watershed Institute, Institute for Earth Systems Science & Policy, California State University, Monterey Bay.  This letter was authored by Dr. Robert Curry, Research Director, and Mr. Dennis Jackson.  You have been told by at least two members of the Council that this letter represents an 'expert geomorphological analysis' of the Fishway proposal.

When this letter first appeared, I chose not to respond since the letter itself was so fraught with inaccuracies and misconceptions that it failed to justify the dignity of a professional response.  The authors never contacted me for clarification of proposal details, nor did they, to the best of my knowledge, attend any of the presentations where I engaged in dialog on the subject.  Their letter was a clear attack against the Fishway proposal, not an objective scientific analysis with the goal of refining the concept.  Their letter lacked adequate technical investigation and familiarity with the proposal.  I personally discussed these shortcomings with Mr. Jackson, but for whatever reason, he chose not to correct the inaccurate analysis.  Then, the Curry/Jackson letter appeared on some internet web sites.  As we are all aware, the internet is an incredible way to spread information and, unfortunately, misinformation.  The internet likewise is generally blind to motivation which is something we should all wonder about given the one-sided nature of this document.  Since this letter was posted on the internet, and because some members of the Watershed Council were unclear about its content, I have chosen to provide you with a formal response.

As an opening point, I would like you to know that not a single public dollar has yet been offered or received for any of the work done on the Fishway proposal since its inception in 1995.  Work has been done at my personal expense and that of the engineering firm noted in the original proposal.  (CDFG did provide the map of the tributaries in Potter Valley.)  As a result, there is a limit to the detail that can be offered at this time.  Hence, my interest continues in seeking funding to conduct some of the feasibility work needed to answer questions and refine the details of the proposal.

Contrary to what one should expect of a reasoned analysis, weighing the pros and cons of a proposal, the Curry/Jackson letter was consistently slanted against the Fishway proposal.  For that reason, I would like to share with you some of the fundamental problems with this letter.  The following is a point-by-point response to the criticisms put forth in the Curry/Jackson letter of February 28, 2000:

Criticism:  Failure to address screening questions

Response:  Screening is a construction detail dealt with at a more advanced stage of planning.  It is an engineering issue which is defined by the regulatory agencies.  Since a complete feasibility study for this proposal would be very extensive, the 'Preliminary Feasibility Study' was to be done on the most primary of factors that might be limiting to the proposal.  The three topics suggested for the early studies were 1) quality and quantity of habitat, 2) hydrology, and 3) sediment transport.   Screening has always been a consideration and would be worked on with CDFG and NMFS at a later stage in project development.  Since this project would open habitat excluded from ESA jurisdiction, it is assumed that current screening criteria could be modified to allow operation during the majority of the migration window, excluding peak flows when fewer of the juvenile fish move, and that screening criteria would focus on older age-class juvenile steelhead.

Criticism:  Point and elevation of diversion

Response:  Questions regarding the point and elevation of diversion were posed in March, 2000 by the Mendocino County Russian River Flood Control and Water Conservation Improvement District.  Their concern was that any diversion point must accommodate the ultimate high water level for the lake, assuming that Coyote Dam could be raised.   These concerns were addressed in later discussions of the Fishway by incorporation of a smaller secondary dam at the inlet to Lake Mendocino that would establish a set diversion point regardless of lake elevation.

Criticism:  Major construction to create the Fishway and removal of several homes

Response:  It has never been claimed that the Fishway is a small project.  Certainly, the original construction of Coyote Dam was not a small project, either.  An entire agricultural community was inundated and and millions of yards of material were moved to create Lake Mendocino.  It is not unreasonable to assume that it may take a major project to reverse some of the damage resulting from that original construction.  To construct the Fishway, very few homes would need relocation, a small fraction of what occurred when the dam was originally built.  Tunneling is also a construction option, though less favorable in some aspects related to fisheries.  This alternative would lessen the need for earth moving and habitat disruption.  The costs for the Fishway are offset by the reality that no other restoration project in California has ever had the opportunity to reconnect anywhere near this amount of lost habitat.

Criticism:  Recreation at Lake Mendocino

Response:  The recreation facilities at Lake Mendocino were constructed knowing that the lake would likely be enlarged; hence those facilities were assumed temporary and built somewhat sparsely.  It is already known that new facilities will be relocated if the dam is raised, Fishway or not.

Criticism:  Disruption of hazardous materials in lake sediments

Response:  Hazardous sediments are normally associated with industrial sites or mining operations.  Neither has been present at or above the lake.  Agricultural chemicals from Potter Valley are a potential a source of contamination, but there has been no documentation of any hazardous materials being present in the lake sediments.  To speculate otherwise seems somewhat reckless and unprofessional since government oversight already requires that all such possibilities be explored and rectified as necessary during any disruption of accumulated deposits.

Criticism:  Repeated references to the difficulty of construction

Response:  I do not know that the authors possess adequate credentials in construction or civil engineering to speak authoritatively on this subject.  New technologies and equipment have greatly improved the ability to do projects once deemed difficult.  One only need observe the many recent highway projects or the rapid reconstruction following natural disasters to see the new level of construction capability.   Many of these newer projects would not have been considered feasible or practical only a few decades ago.

Criticism:  Placement of fine sediments into the Russian River

Response:  It has never been proposed that sediments removed from the lake would be placed in the Russian River.  It was only proposed that the highly gravel-laden alluvial spoils from the Fishway cut through the western hills might be suitable for introduction into the river to replenish lost gravels.  Even the sediment load form the Fishway itself would be enriched in the gravel category since much of the finer suspended sediments would continue to be diverted into Lake Mendocino with the river flow.

Criticism:  Water rights questions

Response:  I have heard numerous discussions and accusations regarding this question.  The consensus seems to point to the fact that the proposed Fishway project is simply a sophisticated fish ladder routed around the north end of the lake rather than next to the dam.  The Fishway will not generally convey large amounts of water.  During summer months, the Fishway most likely will not be operational.  As a fish ladder, water rights may not even be a discussion point.  On the other hand, there may be questions regarding 'point of diversion', or other topics which would require modification of existing rights or issuance of new rights.  These are matters to be reviewed by the State Water Resources Control Board in due course of developing the project as would be the case for any large water-related project.

Criticism:  Fishway operational criteria

Response:  This point has been discussed publicly at length but the authors failed to seek clarification.  Operational details aren't possible without extensive modeling as both these gentlemen should know.  The intent is that during migration months, the Fishway would function as any fish ladder with relatively low flows, possibly in the range of 15 to 50 cfs.  During natural storm events where bedload is mobilized in the East Fork Russian River, flows within the Fishway would be increased to allow those materials to continue movement to the West Fork.   The Fishway will be an engineered sluice channel, allowing a relatively small amount of water, possibly 200 to 500 cfs, to move the bedload.  Quieter sidewaters will be provided like flood plains to provide refuge for fish during these high water periods.  During the warmer summer months, when natural salmonid migration is not occurring, the Fishway could be shut off or used to provide required base flows in the Russian River.  This would be at the discretion of the appropriate agencies.

Criticism:  Natural channels adjust, principal of fluvial geomorphology

Response:  The Fishway is not a natural channel nor is it intended to function as one.  It is a highly engineered channel.  It will be designed and constructed to move fish and sediments.  It will have hardened surfaces.  It will utilize elements from fish ladders and from sluice channels used in mining.

Criticism:  Hydrologically impossible to pass sediment and capture part of the flow

Response:  This statement falsely assumes that the channel coming in and the channel continuing on are of the same size, gradient, and coarseness.  They will not be.  Instead, the Fishway will be narrower, steeper, and smoother with increased sediment carrying capability.  All these factors need to be modeled with the sediment input values.  That is the nature of the proposed feasibility work.

Criticism:  Deposition of bedload at the diversion

Response:  The drawings provided with the original proposal were not intended to depict sophisticated engineering design, only to express the concept.  Obviously, the transition/diversion structure would be designed to maintain velocities, assuring bedload transport.  This would be accomplished by reducing dimensions and increasing grade through the length of the diversion area.  This is not an unreasonable design challenge and is commonly done for many other engineering applications.  If the authors are willing to provide the necessary funding, I would gladly move forward refining some of the hand sketches I have of possible designs for the transition structure.

Criticism:  Increased incision near Calpella

Response:  Incision in much of this reach has already cut the channel down to relatively stable bedrock or clay layers.  Other areas are now armored with the remaining deposits of cobble and boulder.  It is unlikely that the small amount of flow from the Fishway will exacerbate this already serious problem.  It is more likely that any bedload introduced by the Fishway will help stabilize the ongoing problem since there will be a disproportionately high ratio of sediment delivered relative to the Fishway flow.

Criticism:  There may be ongoing expense to remove material from the structure

Response:  Computer modeling as well as demonstration by means of a scale model would be needed to confirm the feasibility of sediment transport in the Fishway.  If this function could not be demonstrated with high certainty, the sediment transport aspect could be modified or abandoned.  Agencies have indicated that the project could still be considered viable if material had to be trucked from a deposition site.  Agency staff have also stated that even if this Fishway never carried one pebble of gravel around Lake Mendocino, the value of re-establishing the lost habitat above Lake Mendocino could justify the project.  Sediment transport is not the primary function of the Fishway; fish passage is.  Sediment transport, if feasible (which we believe it is), can only be considered an added benefit of this project.

'Ongoing expense' needs to be evaluated relative to the high cost that society is currently paying for the protection and restoration of declining numbers of salmonids and for the high cost already paid for loss of viable commercial and sport fisheries.  A potential de-listing of steelhead in the Russian River basin could have significant financial benefit for landowners and taxpayers of the basin.  Likewise, any reduction in incision resulting from the introduction of bedload could produce a significant savings of private and public funds currently being expended for stream bank protection, restoration, as well as for highway bridge replacement, and municipal and private well relocation.

Criticism:  Insufficient gravel to stabilize downcutting

Response:  This is likely true at present.  But the material from the East Fork Russian could lessen the current geomorphic problems in the upper Russian River basin.  This new gravel supply could also provide greatly improved chinook spawning habitat in the Ukiah reach where gravels are highly depleted.  In time, it is likely that other in-channel dams in the upper basin could be modified or relocated to off-channel sites, moving incrementally towards a more balanced sediment budget for the river.

Criticism:  Dredged materials into the Russian River

Response:  This is an inaccurate statement since was not proposed.

Criticism:  Operation independent of the Eel River diversion would strand fish

Response:  The Fishway is intended to function independently of the Eel River diversion.  The Fishway has low water demands and can be curtailed in summer.  The channel is not intended for rearing.  Warming temperatures and declining flows in late spring will naturally move fish out of the system as it moves them out of a natural creek.  Fish rescues are always an easy option should there be any final stragglers.

Criticism:  Loss of recreation facilities

Response:  These facilities were meant to be relocated.  Also, the Fishway is not that large a feature and could possibly be incorporated into future recreational designs offering value for public awareness.

Since Dr. Curry and Mr. Jackson's arguments depended heavily on uninformed speculation to justify why the Fishway concept may not work, their letter should not be construed as an 'expert' geomorphic analysis.  Their analysis lacks in technical accuracy and understanding of the Fishway proposal.   Many of their points were based on false assumptions; hence, it is their analysis that is fatally incomplete and biased.  The format of their letter conveys a mean-spirited attack, the motivations for which may lie with those who commissioned this work.  Some hint as to the inspiration appears in the last paragraph of the letter where Dr. Curry and Mr. Jackson conclude that maybe we could just remove the reservoir to restore fish passage.  Other professionally based motivations also appear to exist.

The team that has worked with me to formulate the Fishway concept is comprised of professionals academically trained in salmonid fisheries biology, hydrologic and civil engineering, geomorphology, sediment transport, and related disciplines.  This team collectively presents many decades of practical experience, successfully completing hundreds of pertinent projects under demanding agency scrutiny.  (Statements of Qualifications have been made available in the past and continue to be by request.)  Likewise, numerous agency staff members from CDFG, COE, and NMFS have reviewed the Fishway proposal, providing valuable input to help refine the concept.  If Dr. Curry and Mr. Jackson share a legitimate concern for the Russian River and are interested in improving its current degraded condition, I invite them to become productively engaged in the Fishway process rather than providing unnecessary distraction.   That way, their issues can be addressed and we can all work towards a viable solution.

Dr. Curry and Mr. Jackson did conclude their letter briefly acknowledging that, 'The main objective of the proposed bypass [Fishway], providing a means for salmon and steelhead to move past Coyote Dam and Lake Mendocino, is a worthy one.'  Being clearly unfamiliar with the Fishway proposal, our community, and for the most part, our river, they failed to comprehend the far-reaching implications of this project.   The potential benefits are far more extensive than the single item they noted.  Allow me to offer a more complete list of the unique benefits and opportunities that I believe the Fishway project can offer to residents of Mendocino County and more generally, to the members of the Russian River community:

• The Fishway project offers unprecedented steelhead habitat restoration (100+ miles), and somewhat less for chinook and coho salmon.
• The steelhead habitat being restored was historically some of the finest in the Russian River basin, estimated at producing an average of over 4,000 adult wild steelhead annually.
• Compared to many streams, the habitat above Lake Mendocino is easily restored due to minimal impacts from past land use.
• The Fishway project has the potential to significantly increase natural production of wild steelhead and salmon below Lake Mendocino both by increasing usable spawning gravels and by increasing the number of spawning adult fish.
• The warmwater sport fishery in Lake Mendocino would be unaffected by the Fishway project.

• The Fishway could significantly reduce sedimentation in Lake Mendocino, increasing the reservoir's life expectancy.
• The Fishway could return natural river gravel to the Russian River below Coyote Dam.
• A restored gravel supply could help stabilize downcutting and bank collapse in the Ukiah Reach of the Russian River.
• Surplus construction spoils could be used for channel restoration of the degraded Ukiah reach.
• Fishway operations are independent of diversion flows from the Eel River.
• Fishway operations will not affect Russian River flow releases or any other lake functions such as water supply, flood control, or recreation.
• There would be little or no effect on the operation of Coyote powerhouse.
• The Fishway is an ideal companion project for the raising of Coyote Dam, a proposal that is currently being discussed.

• The Fishway provides the opportunity for a broad-based community restoration project, fostering substantial community participation and pride.
• There is broad-based agency support for the Fishway concept.
• Steelhead and salmon recolonization would cause minimal disruption to current land-use practices in Potter Valley.
• The Fishway project addresses the biological objectives and goals of the Endangered Species Act.
• Restored steelhead production above Lake Mendocino could lead to a de-listing of that species throughout the entire Russian River basin.
• There is a high likelihood for state and federal restoration funding for the Fishway project.
• Construction of the Fishway project would result in a major influx of revenue to local communities.
• The Fishway offers an interesting opportunity for the residents of Potter Valley and the Potter Valley Irrigation District to negotiate an alternate water source in Lake Mendocino, ending decades of uncertainty over their current water supply.
• The Fishway, if proposed as a companion project to raising Lake Mendocino, may greatly enhance the value of the water supply project, increasing chances for Federal recognition and funding.
• The Fishway, by restoring historical salmonid habitat and providing natural production, offers a superior mitigation for Coyote Dam or any future raising of that dam.
• The Fishway opens an interesting opportunity for Mendocino County to offer a significant mitigation project in lieu of full monetary compensation for raising Coyote Dam, hence trading fish for water.
• The Fishway offers an interesting opportunity for the Army Corps of Engineers to rectify some of the problems that have resulted from Coyote Dam and to use this project as a model for other dam restoration work.
• The Fishway offers an interesting opportunity for National Marine Fisheries Service to craft their first 'Safe Harbor' agreement, a step that must occur if salmonid restoration efforts under the Endangered Species Act are ever to be successful on private lands.
• A 'Safe Harbor' agreement with residents of Potter Valley would likely bring significant financial and/or restoration benefits to involved landowners.
• The Fishway offers an interesting opportunity for National Marine Fisheries Service to restore trust with citizens of the Russian River basin.

The Fishway remains what it has always been, an innovative and intriguing concept in need of community acceptance and the appropriate feasibility studies.  This proposal emulates the Mission Statement of the Russian River Watershed Council--restoration of the wild salmonid fisheries and associated habitats while ensuring a strong, healthy, and diverse economy, all in the spirit of promoting community stewardship.  We live in an altered landscape and must accept that it will take some creative, possibly expensive, engineering solutions to solve problems we have created.  My professional goal has been to seek opportunities to demonstrate that preservation of natural diversity is not an all-or-none proposition, that the choice need not be 'people or fish', but that it can be 'people and fish'.

There is much work to be done on this project.  I am highly appreciative of those members of the Council and the community who have taken the time to review this concept.  I am always receptive to creative criticism and technically sound advice since these help refine the product.  I have very little time for or interest in groundless assertions or inaccurate analysis.

Sincerely,
Park Steiner