Protest – North Gualala Water Company –

Here are Patrick Higgins Comments on the proposed changes in the
diversion – by-pass flows

Thank you ICARE & Living Rivers (Chris Malan) for helping pay for this.

The proposed diversion controls are impossible to enforce.
Coho and estuarine function were not considered in the science presented.
There needs to be storage in place to supplement summer usage
There needs to be a real, enforceable, water use conservation strategy
Additional demand (more units, buildout, and hookups should not be
allowed on this water source (unless there is supplemental storage in place)

Alan Levine
Coast Action Group
Affiliate of Redwood Coast Watersheds Alliance


February 27, 2019

Mr. Mark Matranga

State Water Resources Control Board – Division of Water Rights

P.O. Box 2000

Sacramento, CA 95812 – 2000


North Gualala Water Company

C/O Mr. Alan B. Lilly

Bartkiewicz, Kronick & Shanahan

1011 22nd Street

Sacramento, CA 95816 – 4907


Re: Comments on Fisheries Impacts of North Gualala Water Company Permit #14853 and Application #31792

Dear Mr. Matranga,

I am writing comments on the North Gualala Water Company (NGWC) Application #31792, which would exempt them from North Fork Gualala River low flow requirements under the State Water Resources Control Board (SWRCB) Permit #14853 as well as allow expansion of the service area to allow hook up of more customers. NGWC hired Stillwater Sciences (2013) to assist in preparation of Application #31792 and “to conduct site-specific studies to help determine instream flow criteria that are protective of fishery resources in the North Fork Gualala River.”

My comments are on behalf of the Coast Action Group and the Living Rivers Council and they focus on the impacts of additional diversion called for under Application #31792 on steelhead trout (Oncorhynchus mykiss) and coho salmon (Oncorhynchus kisutch) that have protected status due to their listing under the federal Endangered Species Act (ESA), and California ESA in the case of coho (CDFW 2002).

The logic and science of the Stillwater (2013) report is fundamentally flawed and should not be sufficient for granting the permit alteration request. Stillwater (2013), and other information offered by NGWC, do not constitute California Environmental Quality Act (CEQA) compliance that requires assessment of cumulative effects and how the project will interact with existing environmental stressors.

In fact, the Gualala River ecosystem as a whole is acutely stressed and the NGWC permit request must be viewed in that context. The North Fork Gualala River, from which NGWC extracts water, is one of the last islands of cold-water habitat or refugia suitable for salmon and steelhead left in the entire Gualala River watershed. Also, North Fork cold water flows are critical to maintaining estuarine ecosystem function because thousands of juvenile steelhead reside there. The recommendation that flow diversion rates be altered between November 15 and February 28 when the mouth of the Gualala River is closed is not biologically sound or properly justified (Stillwater 2013.


I have been a consulting fisheries biologist and watershed scientist since 1989 with a specialty in salmon and steelhead restoration. I have contributed to restoration plans for the Klamath River (Kier Associates 1991), South Fork Trinity River (Pacific Watershed Associates 1994), Garcia River (Monschke and Caldon 1992), and San Mateo Creek and the Santa Margarita River in southern California (Higgins 1992). On behalf of the American Fisheries Society, I served as lead author on a Pacific salmon status report for northwestern California (Higgins et al. 1992), which included the characterization of Gualala River coho stocks as at high risk of extinction.

From 1994 to 2003 I helped assemble a comprehensive watershed information system for northwestern California called the Klamath Resource Information System (KRIS) (, and completed such a database for the Gualala River (IFR 2003) as part of the North Coast Watershed Assessment Program (NCWAP)(CA RA 2002). Prior to assisting with the KRIS Gualala database, I created a report that assimilated all literature pertaining to the Gualala River and its fisheries (Higgins 1997) for the Gualala River Watershed Council.

I have also consulted extensively on Gualala River basin timber harvest plans and vineyard conversions for several clients (Higgins 2003a, 2003b, 2004a, 2007). From 2004 to 2010 I served lower Klamath basin Indian Tribes on flow and water quality issues in the Shasta and Scott River basins ( In 2008, I wrote comments for the Redwood Chapter of the Sierra Club on the sufficiency of AB 2121 in terms of restoring flow to North Coast streams (Higgins 2008a) and the sufficiency of the Mendocino County General Plan with regard to salmon and steelhead protection (Higgins 2008b).

Status of Coho Salmon and Steelhead in the Gualala River

NGWC and Stillwater (2013) do not characterize the status of Pacific salmon populations in the Gualala River basin, and in fact they ignore coho salmon all together. Coho recovery is still possible, and they may be occurring in the North Fork Gualala River in low numbers at present, but regardless NGWC must consider impacts of potential flow change impacts on the species. The steelhead population is struggling to survive as the river fills in and tributaries and main river reaches dry up.

Coho Salmon: California Department of Fish and Game (CDFG) historic surveys noted that coho salmon inhabited Buckeye Creek, Fuller Creek, Haupt Creek, North Fork Gualala River and the upper South Fork and its tributary McKenzie Creek (Fox and Quinn 1964; Rowell and Fox 1964, Parke and Klamt 1970, Parker and Pool 1964a; 1964b, 1964c). Coho are now in an “extinction vortex” from the Gualala River south (CDFG 2002), which is the California Central Coast Ecologically Significant Unit (ESU). CDFG (2002) justified listing under CESA as follows:

“Extant populations in this region appear to be small. Small population size along with large-scale fragmentation and collapse of range observed in data for this area indicate that metapopulation structure may be severely compromised and remaining populations may face greatly increased threats of extinction because of it.”

Coho salmon were planted in the Little North Fork Gualala River in 1995-1997 by CDFG (2002), but there was no apparent survival to adulthood or return of adult fish in subsequent years, likely as a result of excess sediment yield related to widespread timber harvest (IFR 2003). CDFG staff failed to find coho salmon in their 2001 habitat survey that covered 100 river miles, as reported in the Gualala River Watershed Assessment (CA RA 2002).   However, CDFG staff did find coho salmon in 2002 in the Little North Fork Gualala River.

NGWC and Stillwater (2013) do not mention coho salmon presumably because they consider them locally extinct and the population to be irretrievably lost. In fact, the adjacent Garcia River basin has had a different trajectory of watershed management and coho salmon are present (MRC 2002) and in recovery the South Fork Garcia River because of road decommissioning and watershed restoration (IFR 2003). Recolonization by coho salmon of the Gualala River is still possible. Little fish survey data are provided in the application; therefore, we don’t know if coho salmon are trying to rebound or remain absent. Chinook salmon population problems in the Central Valley and Klamath-Trinity have and will continue to constrain ocean commercial salmon fisheries. Therefore; CCC coho may experience a resurgence due to less fishing pressure and higher ocean survival. The National Marine Fisheries Service (NMFS 2010) lists the North Fork Gualala as core area for CCC coho recovery. Consequently, NGWC needs to conduct periodic coho salmon presence/absence surveys and include potential impacts of flow changes on juvenile coho salmon.


Steelhead Trout: Steelhead in the CCC ESU, including in the Gualala River, were listed by NMFS (1997) as threatened and their status was reaffirmed in 2005 (Good et al., 2005). Taylor (1978) estimated the annual Gualala River adult steelhead population at 16,000 fish in the early 1960’s prior to the 1964 flood. Boydstun (1976a, 1976b) estimated that the 1974-75 steelhead run was 7,608 adults based on mark recapture data and the 1975-1976 run was estimated at 6,300 fish. Boydstun (1974) noted that while angler effort in 1972-73 was 60% greater than in 1953-55, the catch in the 1970’s was just 25% of the 1950’s catch. He attributed the decreased catch rate to decreased adult steelhead abundance.


Long term CDFG studies of the North Fork Gualala River showed that the standing crop of steelhead juveniles was reduced in abundance from 1988 to 1999 (Figure 1) and yearling and two-year-old steelhead became extremely rare (IFR 2003). This was because logging by Gualala Redwoods Inc caused excess sediment yield, stream warming, pool filling and gravels too choked with fine sediment to support spawning and insect production (IFR 2003).


Despite the widespread freshwater rearing habitat problems in the Gualala River watershed, DeHaven (2010) counted as many as 1400 adult steelhead spawners on the Wheatfield Fork of the Gualala River, indicating a population of adult steelhead in the thousands at least in some years. The reason is the productivity of the Gualala River estuary. ECORP and Kamman (2005) sampled the Gualala River estuary with seine nets in 2002 and 2003 and estimated populations of steelhead trout that were yearling size (4 inches) or greater. In 2002 they estimate that from 2,389 to 9,496 older age steelhead juveniles were in the estuary and in 2003 their estimate was 9,994 to 28,814. Since larger steelhead juveniles have a higher survival rate in the ocean (Barnhardt 1986), the standing crop of juveniles in the estuary could easily produce and adult run in the thousands in years of good ocean survival (Groot and Margolis 1991).


Gualala River Habitat Conditions and Ecosystem Function


Severely aggraded tributaries other than the North Fork were shown to be dewatered in extensive reaches (Figure 2) during CDFG 2001 habitat surveys (CA RA 2002), which means a substantial reduction in habitat for native fishes, including steelhead. Fox (1964) surveyed the Wheatfield Fork in 1963 and found 200 steelhead juveniles per hundred feet of stream, with steelhead comprising 80% of the fish community and Gualala roach only 20%. CDFG 2001 surveys of the Wheatfield Fork found the fish community dominated by the endemic, warmwater adapted Gualala roach (Figure 3). This shows an ecological shift from a cold-water ecosystem to a warm-water one. While the Gualala River maintained surface flows in 1976-1977 in the lower South Fork and Wheatfield Fork, the drought of record at that time, both branches went dry in extensive reaches in 2001, even though there was more rainfall that year (IFR 2003). These reaches again became dewatered as a result of the 2013-2015 drought. Changes in watershed hydrology, additional water withdrawals by vineyards, and aggradation have crested severe ecological stress for the Gualala River. Many tributaries that formerly served as refugia go dry also, including Buckeye, Rockpile, Robinson, McGann and Pepperwood creeks.

Figure 1. Electrofishing data collected by CDFG in the lower Little North Fork Gualala River showing that steelhead decreased in number and density from 1988 to 1999. (IFR 2003).


Figure 2. CDFG habitat typing data (CA RA 2002) show that extensive reaches are underground as a result of aggradation.

Figure 3. Electrofishing data associated with habitat surveys indicates that the Wheatfield Fork of the Gualala River had almost no steelhead in 2001, whereas it was dominated by steelhead juveniles in 1974 (Cox 1974).


Although not listed under federal of State ESA statutes, the native Sacramento sucker is an indicator of the degree of ecological degradation of the Gualala River. The species is adapted to warm main river environments where it eats algae off stream substrate. German (1966) reported that northern California rivers were dominated by suckers after the 1964 flood, which was also true of the Gualala River (IFR 2003). CDFG basinwide habitat surveys (CA RA 2002) included many miles of main river habitats and found no suckers. The combination of winter turbidity and bedload movement and summer stream channel desiccation appear to have extirpated this key-stone warm-water species.


The North Fork Gualala River is one of the last cold-water habitats in the entire Gualala River basin. Therefore, it takes on greater significance in terms of its role in protection and recovery of steelhead and coho populations that must be considered when evaluating the NGWC application. It also plays a critical role in maintaining estuarine health.


Potential NGWC Impacts to the Gualala River Estuary


The reason the steelhead run in the Gualala River is able to maintain itself under such adverse selective pressure is because of the extensive Gualala River estuary and lagoon that can harbor thousands of older age juvenile steelhead (Brown 1986, ECORP and Kamman 2005). The occurrence of numerous young of the year steelhead in the estuary, that would normally spend their first year in small streams, is indicative of the lack of habitat for the species elsewhere in the basin (ECORP and Kamman 2005). Continuing excessive stream diversion of the Gualala River and contributions of excess sediment and nutrients, in combination with climate change, are likely to push the estuary/lagoon past a tipping point where it becomes more eutrophic and ultimately anoxic. At that point the steelhead population of the Gualala River would collapse.

Brown (1986) found that steelhead extensively used the Gualala River estuary for rearing. Cannatta (1998) studied the nearby Navarro River estuary. The Navarro River has similar problems with aggradation and desiccation to the Gualala River (IFR 2003). Using a beach seine and Peterson mark-recapture technique, Cannatta (1998) estimated that between 3,000 to 9,000 yearling and two-year old steelhead reared in the Navarro estuary during summer. The findings of ECORP and Kamman (2005) are recounted above and show even higher standing crops of older age steelhead. The ability of the Gualala River estuary to support two-year-old steelhead is critical because they need to attain that age and a size of greater than six inches in order to survive in the ocean (Barnhardt 1986).


Given the problems with lack of flow, and potential for nutrient enrichment from newly developed vineyards or leaking septic systems, the potential for Gualala River to become eutrophic is real. This means that nuisance algae blooms could form causing wide swings in dissolved oxygen and adverse conditions for steelhead rearing. ECORP and Kamman (2005) report conditions symptomatic of euthrophication:


“Estuarine sampling upstream of the Highway 1 bridge became difficult due to dense blooms of filamentous algae. ……… In general, filamentous algae is pervasive throughout the lower river and in some areas of the estuary from mid-summer through late-fall…. Nutrient loading can and may occur in the Gualala River watershed from anthropomorphic sources, such as agricultural runoff, campgrounds, and septic systems.”


ECORP and Kamman (2005) measured dissolved oxygen and found concentrations of 9.6 and 10.3 mg/L, which are super-saturated and symptomatic of high photosynthetic activity (Goldman and Horn 1981). While algae blooms elevate concentrations of DO during the day, algae nocturnal respiration may cause DO sags that can be injurious to salmonids. No nocturnal DO levels were measured, but ECORP and Kamman (2005) noted that:


“Seasonal senescence and eventual bacterial decomposition of the aquatic plants can lower DO levels during the late summer, particularly when flows from upstream are reduced and wave-wash over the sandbar is nonexistent. The relatively small size of the estuary and perennial freshwater inflow are important variables in maintaining a freshwater dominated, health estuary.”


“Plant matter present during the late summer probably undergoes bacterial decomposition, releasing more nutrients into the cycle, but not to the point of eutrophy because freshwater inflow prevents the lower river from stagnating.”


The cold water coming out of the North Fork Gualala is not just important for conditions immediately downstream of the mouth, but also the entire estuary. The estuary is kept somewhat cool by fog in summer and its water quality also benefits from wind mixing. However, cold water from stream flow in summer, including the North Fork Gualala, can help form a cold-water layer at depth that can buffer the estuary and help moderate its temperature. Therefore, as much flow as possible is needed from the North Fork Gualala in summer, regardless of fish passage issues or local habitat in the lower North Fork.


Validity of Stillwater Modeling Results


Stillwater (2013) did a habitat inventory in 2012 of the North Fork Gualala River upstream and downstream of the NGWC wells and measured riffle cross sections and depth at transects. The riffle measurements were used to show that small changes in depth of riffles due to diversion during low flow conditions requested in Application #31792 would not prevent fish passage and diminish steelhead survival. The North Fork Gualala is fluid and ever-changing; therefore, model results would not be repeatable because of bed changes. Also, basing discussion of survival of migrating salmonids on depth alone does not account for interaction with predators.

Bedload Mobility: Excess sediment yield in the Gualala River basin is manifest in small median particle size (D50) distribution (Knopp 1993). This small D50 promotes bedload movement that is lethal to salmonid eggs and fry (Nawa et al 1990, Nawa and Frissell 1993). Consequently, streams with a D50 less than 45 mm like many Gualala River sites (Figure 4) are non-functional for salmonids in terms of spawning suitability (Reeves et al. 2003). Bedload mobility and excess fine sediment in transport can also decreases aquatic macroinvertebrate production that is a principal source of food for juvenile salmonids.


Substantial data from the Little North Fork prior showed major sediment over-supply that was causing riparian mortality and an increase in fine sediment in stream gravels (IFR 2003). Timber harvests have continued in the North Fork and sediment yield is likely still elevated. High flow years like 2016-2017 can cause evacuation of sediment stored in pools and upland reaches of streams, rejuvenating habitat for juvenile salmonid rearing. However, low gradient reaches such as the North Fork Gualala above its convergence with the South Fork that the NGWC pumps are “response reaches” where sediment tends to be stored (Montgomery and Buffington 1993). As these sediment deposits stall, they may create riffles with much shallower crests. Therefore, it is likely that the modeling results of Stillwater (2013) no longer apply as depths change annually and may be much shallower in some years.


Fish Survival During NGWC Reach Passage: The North Fork Gualala ecosystem has a vertebrate predator community that includes herons, egrets, king fishers, osprey, bear, coon, otters and garter snakes that dine on juvenile salmonids. Less water, means less cover, means more predation. If water is 6 inches deep, there are reflections and shadows that may allow juvenile salmonids to slip by predators unnoticed, while the v-shaped ripple of a fish moving in too shallow water may make them more subject to predation. Therefore, Stillwater (2013) models cannot be used to justify increased diversion when flows drop below the minimum of 4 cfs from June 1 to November 14. Analysis of flows for adult passage are similarly flawed.


Figure 11. South Fork Gualala stream beds show very small D50 size that make them unsuitable for spawning due to bed load mobility that will cause changing conditions at NGWC riffles.

Changes in Bypass Flow Requirements Based on Estuary Bar Breaching: The request for changes in minimum bypass flow recommended by Stillwater (2013) when the estuary bars up in winter are not biologically justified. During low flows between November and February, when a minimum of 40 cfs is required in the North Fork, Stillwater (2013) recommends that pumping be allowed even if this level is not met after two weeks following the formation of a sand bar that blocks connection of the estuary to the ocean. Adult steelhead and coho salmon may enter the estuary and reside there or in pools below the North Fork for weeks or months under low flow conditions in winter after the mouth has closed. Their access to the North Fork Gualala River would be impeded or made more difficult by reduced flows proposed in Application #31792.


Need for Water Storage and Water Conservation


Stillwater (2013) says that even when flows drop to below the minimum by-pass level of 4 cfs after June 1, “NGWC still must pump these wells to meet the demands of its municipal water customers during such conditions.” This is a major problem since data filed with the NGWC application show that water use rises from July through September, which is at exactly the same time that critical North Fork Gualala River low flows occur. NGWC should have pursued additional off-stream storage to meet demands in drought years during summer peak use, when the flow is less than the minimum required for by-pass. Mandatory conservation measures and installation of drought resistant landscapes and greywater systems are needed to decrease demand. Expanding the area served by NGWC and allowing more hook-ups as requested in Application #31792 without construction of additional storage and implementation of mandatory conservation measures would be irresponsible and diminish the ability of the North Fork Gualala River to support endangered salmonids and to buffer the estuary that is critical to steelhead survival.


Compliance with Minimum Flow Requirements


Minimum flows under Permit #14853 are listed below in Table 1.


Table 1. North Fork Gualala River minimum by-pass flows under Permit #14853.


Dates Minimum Flow
November 15 – February 28 40 cfs
March 1 – May 31 20 cfs
June 1 – November 14 4 cfs


The reduction from 40 cfs to 20 cfs at the end of February seems rather arbitrary, given that adult steelhead spawn timing extends well into March and April in the Gualala River (DeHaven 2010). Stillwater (2013) suggests that NGWC could draw water from their well even when the flow of the North Fork is below 4 cfs, and as low as 1 cfs. They suggest that the water system operator can extrapolate from the USGS gauge value and never take more than 10% of the flow.


U.S. Geologic Survey flow data from the North Fork Gualala River immediately downstream of the NGWC wells from July 1 to October 1, 2018 show that minimum bypass requirements of 4 cfs were not met for much of the latter part of August into late September (Figure 5). There is currently no system to audit compliance with minimum flow requirements set by Permit #14853, which needs to be corrected. The assumption by Stillwater (2013) that plant operators could make minute adjustments by extrapolating values from the USGS gauge stretches credulity, and means that an NGWC operator could accidentally dry the stream up and there would be no way for regulatory agencies to determine whether this had occurred.



Figure 5. USGS North Fork Gualala River flow data for July 1 to October 1, 2018 shows that minimum flow requirements of 4 cfs were not met for extended periods in August and September.




Additional diversion from the North Fork Gualala River by the NGWC as requested under Application #31792 when minimum bypass flows required by Permit #14583 are not met will harm ESA listed Pacific salmon species and should be rejected. Stillwater (2013) does not provide scientific data to support such diversions and in fact their models that are supposed to show that bypass flows are safe for fish are invalid because riffle crests depths constantly vary. Additionally, shallower riffle crest depths would increase vulnerability of adults steelhead and juveniles to predation, but Stillwater (2013) ignores this factor. There is no clear rational offered for allowing continuing NGWC North Fork Gualala diversion when minimum flows of 40 cfs for adult passage are not met during winter because the sand bar in the estuary has formed.


The Gualala River ecosystem is in a state of collapse with viable cold-water fish habitat becoming rare. The North Fork Gualala River is the last refugia and needs more protection, not less. NGWC and Stillwater (2013) ignore the need to maximize cold freshwater flows from the North Fork to buffer the estuary from warming and help prevent it from passing a tipping point where it becomes too eutrophic to support juvenile salmonids.


NGWC needs to fully implement conservation measures to meet water demand instead of being allowed to divert water during critical low flow periods in violation of Permit #14853.



Patrick Higgins



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Poole, G.C., and C.H. Berman. 2000. Pathways of Human Influence on Water Temperature Dynamics in Stream Channels. U.S. Environmental Protection Agency, Region 10. Seattle, WA. 20 p.

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Rowell, J., and B. Fox. 1964. Fuller Creek Stream Survey. Fuller Creek from mouth to forks 4.25 miles upstream on foot and by vehicle (hand drawn map, description and dimensions of log jams). August 18-l 9, 1964. California Department of Fish and Game, Region 3, Yountville, CA. 2 p.


Stillwater Sciences. 2013. North Gualala Water Company pumping limit recommendations. Prepared by Stillwater Sciences, Arcata, California for North Gualala Water Company, Gualala, California. 20 p.


Taylor, S.N. 1978. The status of salmon populations in California coastal rivers. California Department of Fish and Game. Salmon/Steelhead Program, Anadromous Fisheries Branch. 14 pp.