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Post Office Box 506 Santa Cruz, CA 95061 | 831-423-3191 www.ventanawild.org vwa@ventanawild.org |
Kyriacos C. Kyriacou
State Water Resources Control Board
P.O. Box 2000
Sacramento, CA 95812
November 4, 2002
SUBJECT: El Sur Ranch/Hill Application for Permit to Increase Pumping of the Big Sur River
Dear Mr. Kyriacou:
The Ventana Wilderness Alliance (VWA) is a 501(c)3 non-profit organization that works to promote the conservation and careful stewardship of resource values in the northern Santa Lucia Mountains. We appreciate the opportunity to provide the following comments regarding the El Sur Ranch application to increase annual pumping of the Big Sur River to 1800 acre-feet.
The Big Sur River was designated a Wild and Scenic River in 1992. The entire upper watershed of this undammed and free-flowing river is federally protected, however the lower reaches of the stream running through state and private lands are subjected to numerous small water diversions. The VWA is concerned that a significant increase in pumping from the Hill wells in the downstream region of the Big Sur watershed will dramatically impact underflow of the Big Sur River. An increase in pumping to 1800 AF will have substantial impacts on the following public trust resources:
- Riparian Vegetation: Well diversions result in repeated watertable drawdown and stress to riparian vegetation. Moisture stress in the cone of depression and throughout the root zone of the riparian corridor will reduce plant vigor and can lead to mortality of streamside vegetation. Mortality of vegetation in the riparian corridor can result in streambank erosion, siltation of valuable spawning gravels and macroinvertebrate habitat, as well as reduced cover and shade for both terrestrial and aquatic species.
- Steelhead: The Big Sur River is a very important resource for steelhead, a Federally Threatened species. Any significant increase in pumping from the Hill wells may dewater reaches of the lower Big Sur River used by steelhead. Any detrimental impact on steelhead habitat could be considered "take" under the Endangered Species Act.
- Big Sur River Lagoon: The mouth of the Big Sur River is characterized by an important estuarine habitat. This coastal wetland provides valuable rearing habitat for juvenile steelhead and is utilized by a variety of birds and other wildlife species. Increased pumping from the Hill wells may dewater the Big Sur River Lagoon or otherwise impact water levels and numerous water quality parameters.
- State Park Property: The Hill wells are located on land owned and managed by the California Department of Parks and Recreation. Increased use and corresponding maintenance of these wells may result in conflicts with visitors to Andrew Molera State Park and potential impacts to the park visitor experience with noise, maintenance crews and equipment.
- Cumulative Impacts: The environmental review of the Hill water rights application should evaluate the potential growth inducing impacts that may result from the increased availability of water in the Big Sur region. The pressure for water to service developable residential and commercial lots is extreme within the Big Sur River watershed. A thorough assessment of environmental impacts associated with the Hill application must include an evaluation of the potential cumulative impacts associated with the provision of an additional 1800 AF of water that could be used for development purposes
Thank you for the opportunity to share our concerns with the Hill application to increase water diversions from the Big Sur River. Please add the Ventana Wilderness Alliance to your mailing list to receive future correspondence regarding this issue.
Sincerely,
Steve Chambers
Vice President, Ventana Wilderness Alliance
