Comments on Draft EIR for Fish Habitat Flows and Water Rights Project

Click here to read our comments on Sonoma County Water Agency’s Fish Habitat Flows and Water Rights Project prepared by Shute, Mihaly, & Weinberger LLP. Learn more about the project here.

A summary of our comments:

I. The EIR fails to adequately describe the project

II. The EIR fails to analyze or mitigate environmental impacts of proposed deadline extension for completing full beneficial use of water diversions. The agency is essentially asking for increased water rights in the amount of 10,000af in proposing this deadline extension.

III. The EIR fails to analyze cumulative impacts.

Conclusion
As set forth above, the DEIR suffers from significant deficiencies, many of which would independently render it inadequate under CEQA. Taken as a whole, the deficiencies of the DEIR necessitate extensive revision of the document and recirculation for public comment. FOER respectfully requests that the Agency provide the requested information regarding impacts to the Eel River and illegal diversions from the Russian River so the public and decision-makers may make informed decisions about the Project and mitigation measures.

Review exhibits from our comments here.