Helping Our Peninsula's Environment


Threat to Carmel River from "science" report falsely claiming the river only needs a trickle of water.

(c) Copyright 2003 David Dilworth

Possibly the most dangerous document ever written about the Carmel River just surfaced in January 2003. Your help is needed.

When the Water Management District Board asked for it, the report was supposed to show what flows are needed to restore and maintain the Carmel River habitat for the imperiled species which depend upon it including the West Coast steelhead and the California red-legged frog. 

The report, given to the board Jan 30, 2003 (but thankfully not officially received), claims that only a trickle of water is necessary for the fish to survive.(1) The lower the flows -- the worse for fish and frogs, and the better for developers.

The report claims it is only restating what other scientific studies report. But under questioning from one Director, the report's author from Jones & Stokes admitted that the minimum water flows recommended by the federal agency experts responsible for restoring the Steelhead habitat (NOAA) were "significantly higher."

This report is dangerous because its flow recommendations could still be used to determine how much MORE water developers can pump from the Carmel River for more development, more golf courses and even worse - justify a new dam. The report was intended for "Environmental Impact Significance Thresholds" determinations for the Dam Environmental Impact Report (EIR). If the thresholds of significance are set at very low water flows - it means a new dam and increased pumping are easier to justify.

What's wrong?
Just a few of the report's problems include --

  • The report's goal is backwards - to maximize river pumping - not to restore the river. The report is supposed to show what flows are needed to restore and then sustain the ecological phenomena with a reasonable margin of safety. Instead, the report makes every attempt to maximize and justify overpumping of the river.
  • Loss of Elasticity -- As was carefully pointed out by Steelhead Association spokesperson Roy Thomas, the report ignores the need to use a margin of error and it fails to use the Precautionary Principle. These are both vital because the large natural variations in rainfall (e.g. droughts) and river flow alone will present challenges to the fish and frogs sustainability. Our existing overpumping, a new dam and a potential pumping increase on top of those problems could be permanently fatal to the fish and frog species. The report's simplistic conclusions are ludicrous in light of the highly complex and little understood science of species and river interdependence involved.
  • Upstream Ignored -- The report ignores impacts on fish upstream of the existing Los Padres Dam spillway; even those who live in its reservoir. Young fish cannot find their way through a reservoir because there is essentially no downstream flow. Reservoirs also cause aggradation which is when a dam begins to fill with silt and the silt accumulates upstream of, and higher in elevation than, the reservoir surface. This can harm upstream tributaries by blocking fish migration.
  • Birds -- The report completely ignores impacts on birds. 
  • Flushing Flows -- The report almost completely ignores flushing flows desperately needed by the California red-legged frogs. Flushing flows are vital to these native frogs because the flows literally flush their primary non-native predator, the bullfrog, out to sea. California red-legged frogs are not flushed out, because they know to leave the river area when it starts to rain. I say the report "almost" ignores flushing flows. Directly contrary to the science it is supposed to be restating, the report actually claims that "increasing flows is [harmful to the imperiled frogs]." 
  • The reports only uses 44 years of data, ignoring historical droughts that have lasted 100 to 200 years and more in our recent millennium.
  • The report fails to state, understand or incorporate the genuine legal threshold for a mandatory significant impact to an imperiled species -- which is the death of a single individual or any (2) of their habitat. (CEQA section 15065)

Perhaps the biggest outrage is that the consultants were PAID for this poor report and the UNPAID public now has the burden to complain, and provide the evidence and reasoning to clean up the damage and essentially do the consultant's work for them!

Please call your Water District Boardmember today and urge them to --

  • Reject this report. This report cannot be re-written, it must be restarted because the authors started off in a very wrong direction with the wrong assumptions. 
  • Restart with a different consultant. This consultant has clearly failed this extremely important job in a dangerous way. No one who fails this badly should get a second chance.
  • Remove the consultant from any future contracts with this agency.
  • Adopt a policy that consultants shall be removed from all future contracts with this agency when they do poor science.


(1) "Minimum daily flow of 1-5 [cubic feet per second] at Narrows..." Table ES-1, page 2 of 2 Dangerous Flow Report by Jones & Stokes (PDF - 9 megabytes)

(2) An Appellate Court found that the loss of as little as a quarter of an acre of imperiled species habitat is a clearly significant environmental impact. (Mira Monte Homeowners Assoc 165 Cal. App 3rd 357)

For related information see "Biostitute" in our Glossary

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This Page Last Updated February 4, 2003