The Proposed Water Rights Reform Is Not Enough The WRD study focuses on how much winter flow salmon and steelhead need for migration and spawning, but doesn’t even discuss low summer and fall conditions that are known to be more limiting. No action is disscussed regarding removal of more than 1771 illegal diversions and dams in the Policy area acknowledged in Appendices. The Policy does not cover the Klamath and Eel rivers, which have greater potential for fish recovery and greater identified water rights enforecement needs. The Policy does not cover riparian water rights, which do not require a Permit and, consequently, will likely confound any allocation planning. WRD ignores groundwater withdrawal in the Policy despite the fact that increased appropriative water rights permit difficulty or cost is likely to increase well use and that groundwater use is recognized as contributing to surface water depletion and loss of fisheries productivity in the region. The WRD has not enforced California Water Code § 1052, 1055, 1243, and 1375 , nor leading to an epidemic of illegal dams that have dried up North Coast salmon and steelhead streams. Section 1601/1603 Permit. The California Department of Fish and Game (CDFG) requires notification for any project or activity that will take place in or in the vicinity of a river, stream, lake, or its tributaries, including any construction project that will: (1) divert, obstruct, or change the natural flow or the bed, channel, or bank of any river, stream, or lake; The Policy fails to meet California Environmental Quality Act (CEQA) requirements of dealing with cumulative effects: 1. All the diversions acting together cause problems off site. 2. Changes due to land use have caused reduced water supply and water availability that need to be considered in Water Rights Permit issuance. The Policy proposes to use Watershed Groups to fund studies, assess flow availability, and mitigate all problems related to diversions, but these groups are defined as “a group of diverters in a watershed who enter into a formal agreement to effectively manage the water resources.” In other words, the WDR wants to turn water allocation over to diverters!

The Proposed Water Rights Reform Is Not Enough

•The WRD study focuses on how much winter flow salmon and steelhead need for migration and spawning, but doesn’t even discuss low summer and fall conditions that are known to be more limiting.
•No action is disscussed regarding removal of more than 1771 illegal diversions and dams in the Policy area acknowledged in Appendices.
•The Policy does not cover the Klamath and Eel rivers, which have greater potential for fish recovery and greater identified water rights enforecement needs.
•The Policy does not cover riparian water rights, which do not require a Permit and, consequently, will likely confound any allocation planning.
•WRD ignores groundwater withdrawal in the Policy despite the fact that increased appropriative water rights permit difficulty or cost is likely to increase well use and that groundwater use is recognized as contributing to surface water depletion and loss of fisheries productivity in the region.
•The WRD has not enforced California Water Code § 1052, 1055, 1243, and 1375 , nor leading to an epidemic of illegal dams that have dried up North Coast salmon and steelhead streams.
•Section 1601/1603 Permit. The California Department of Fish and Game (CDFG) requires notification for any project or activity that will take place in or in the vicinity of a river, stream, lake, or its tributaries, including any construction project that will: (1) divert, obstruct, or change the natural flow or the bed, channel, or bank of any river, stream, or lake;
•The Policy fails to meet California Environmental Quality Act (CEQA) requirements of dealing with cumulative effects:

1. All the diversions acting together cause problems off site.

2. Changes due to land use have caused reduced water supply and water availability that need to be considered in Water Rights Permit issuance.

•The Policy proposes to use Watershed Groups to fund studies, assess flow availability, and mitigate all problems related to diversions, but these groups are defined as “a group of diverters in a watershed who enter into a formal agreement to effectively manage the water resources.” In other words, the WDR wants to turn water allocation over to diverters!