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To whom it is of concern:

The following statement I submitted to Cal-Fed ( Coalition of California
State and Federal Regulatory Agencies) in regard to the latest feeble
attempt to fix the broken Sacramento - San Joaquin delta-San Francisco
Bay ecosystem by use the sophisticated engineering  alternatives built in
the Delta whose controversial  plumbing will further facilitate systemic
water starvation of the deltaic migration, spawning, breeding, and
feeding ground for estuarine-depended fishes and else. 





May 5, 1998

CalFed Public Hearing
University High School
4771 Campus Drive
Irvine, CA 92716 


Subject:  March 1998 Draft Programmatic EIS/EIR
______________________________________________________________________________

On the subject of CalFed's EIS/EIR, I would like to bring to your
attention that the major threat to Californian riverine and coastal
ecosystem health and sustainability is caused by excessive impoundment of
rivers by dams and the subsequent water diversion for human usage.
		 We must remember that Nature has a limit, and work
wisely within that framework to serve humankind. 
	The significance of this threat to the Nation's water quality and
resources of coastal ecosystems and their economics and societal
infrastructure has not been appropriately recognized or appreciated by
CalFed.  As a result of dams and diversions, coastal ecosystems have been
suffered from immense economic and ecological penalties similar to that
documented in the former U.S.S.R. (Rozengurt and Herz 1981; Rozengurt, et
al. 1985, 1987; Rozengurt and Haydock 1981, 1991, 1993).
	Since the late 1960s in the former U.S.S.R., 30 major and 100s of
minor dams on rivers of the Black, Caspian, Azov, and Aral seas' basins
have retained 60 to 97% of spring freshwater flux.  Subsequently, this
impoundment and enormous cumulative losses of over hundreds of 
millions of acre-feet (hundreds of cubic kilometers) of runoff have
inflicted a mortal blow to habitat and destroyed migration, spawning and
nursery grounds of 90-98% of the valuable species of recreational and
commercial fish in the southern U.S.S.R.  Economic losses for fishery
alone have amounted up to $4 to 5 billion per year with thousands of
boats and hundreds of thousands of fishermen out of work.
	Today, no one in Russia uses the word "restoration."  All
attempts to restore the fisheries have failed  - the current habitats
have nothing in common with their teeming past.  Within just twenty
years, all seas were transformed into "blue deserts."
 
The Aral Sea has ceased to exist.  Salt dust and toxins blown from the
sea bottom fell back to earth and destroyed crops for hundreds of miles
downwind.  Contaminated drinking wells make  the infant mortality in
Central Asia's  ( the  Aral Sea  watershed) nearly five times the Soviet
average - a staggering 10 to 20% of all babies born.  (Is this a future
threat to the Owen's Valley population?) 
	In general,  since the 1970s  the southern watersheds of the
former U.S.S.R. have symbolized management's staggering ignorance of
major Laws of the Universe (thermodynamics) which govern ecosystem
sustainability (Rozengurt, 1993, 1994, Rozengurt and Hedgpeth, 1997).  As
a result, the past misguided search for short-term economic gain has not
been rectified by an overhaul of the entire system.
	  Unfortunately, California's water management appears to follow
the same path of the entire arid and semi-arid southwest "Sunbelt" where
burgeoning water development is only slightly less ominous than that in
the Black, Azov, and Caspian seas' watersheds (Rozengurt and Hedgpeth,
1989).

I determined for Russian rivers over twenty years ago, and in the 1980s
for the Sacramento - San Joaquin rivers, that when annual water
withdrawals exceed 30% (or 50 to 90% of normal spring runoff) then the
estuary's natural functioning is largely destroyed or brought to the
brink due to enormous cumulative water deficits and watershed
desiccations by dams and diversions.  Other examples, besides the
Sacramento-San Joaquin river delta-San Francisco Bay-coastal ecosystem
are:  the Snake River/Columbia River and coastal zone;    Florida's
"Everglades," and Florida, Tampa, and Charlotte bays;  the Nile River
Delta;  some 40 estuaries of the Gulf of Mexico, especially several in
Texas; and the Chesapeake Bay ( Halim, 1991;  Robinson 1981; Rozengurt et
al., 1987b; Simenstad et al., 1992;).  
	This implies the following summary facts:
(1)  all these systems and the entire Central and South Atlantic and
Western Pacific coastal waters have been deprived of many thousand
millions of acre-feet of runoff that it is vital for their survival;
(2)  the remnants of residual or "regulated" flow often correspond to an
actual dry year or a chronic drought condition from the perspective of
functioning of ecosystems regardless of wetness of the year;  and 
(3)  progressive entropy (system agony resulting from Second Law of
Thermodynamics) is now a permanent feature of human-influenced riverine -
deltaic - estuarine- coastal ecosystems' regime. 

The cumulative effect of these related processes eventually leads to the
demise of the water body itself (for example, the Delta-San Francisco Bay
system), the same as we would die of such a constant hemorrhage of our
blood. In addition to destroying valuable fisheries, large-scale
freshwater diversions have jeopardized the deltaic drinking freshwater
intakes themselves due to an inexorable increase of brackish or salty
water intrusion (Second Law) and made some formerly lush regions
uninhabitable to humans (example, Aral seas, Owens Lake, Colorado Delta).

In terms of relative scale, I believe that flow diversions dwarf both
wetlands' losses and pollution as threats to the "health" of coastal
ecosystems and their living marine resources.

This threat of continued excessive water diversions on the California
water resources should be a primary focus of called.  However, they have
allocated no funds to address this problem and no mention is even made in
their studies.  [This same lack of recognition is reflected in the EPA's
Environmental Monitoring and Assessment Program (MAP), and in USES  water
quality studies.] 

I believe that called should therefore be directed to provide the
leadership in assessment of limitations in water development as it
affects fisheries and other resources.  Their immediate task should be to
review the full significance of the threat and to formulate plans based
on natural sustainability and the environmental, economic, and societal
compatibility of water development by different water users.  This may
halt trends apparent here and already realized in the despoliation of
former Soviet Union's estuarine - marine ecosystems.  Such work would be
invaluable for alternative political, economic and ecological
decision-making by California's administration.
	I urge you to facilitate a more rational water policy based on
the fact  that: 
1.  California possesses only 28.5 MAN of normal, unimpaired runoff over
a perennial period (averaged over 60 years) in the Sacramento - San
Joaquin watershed.  This amount determines entirely the survival of the
Delta - San Francisco Bay and the State's precious coastal resources;
2.  Spring runoff, the lifeblood of any water system, has already been
reduced to 10 to 30% of what once was around 11 MAF on average (as
computed over 55 to 60 years, averaged, normal, unimpaired runoff); 
3.  Since 1955 the Bay has deprived over 600 MAF(million - acre- feet, or
720 cubic kilometers) of freshwater runoff, and millions of tons of
organic and inorganic matter, suspended sediment, oxygen, and etc. left
behind the dams and in water conveyance facilities; 
According to physics, "No one can get something from nothing." 
California's water management has already reached NOTHING.  Any talk
about "Restoration" of the Delta or Bay is a dangerous fallacy!  I
appreciate this opportunity to comment on CalFed's ambitious but flawed
report.
							
Sincerely,
Michael A. Rozengurt, Ph.D.,P.H.
Physical Oceanographer and Hydrologist
Huntington Beach, CA

REFERENCES CITED:

1. Halim, Y. 1991. The impact of human alterations of hydrological cycle
on ocean maregin. In Ocean Margin Processes in Global Changes (Eds.
R.F.C. Mantoura, J.M.Martin and R.Volast). John Wiley & Sons lTD
2. Robinson, A.E.  1981.  Chesapeake Bay low freshwater inflow study. 
In: R.D. Cross and  D.L. Williams (eds.), Proceedings of the National
Symposium on Freshwater Inflow to Estuaries II:114-127.  U.S. Department
of the Interior, Washington, D.C.
3. Rozengurt, M.A. and M.J. Herz.  1981.  Water, water everywhere but
just so much to drink. (pp. 65-67)  Oceans.  Sept.
4. Rozengurt, M.A. and I. Haydock.  1981.  Methods of computation and
ecological regulation of the salinity regime in estuaries and shallow
seas in connection with water regulation for human requirements.  In:
R.D. Cross and D.L. Williams (eds), Proceedings of the National Symposium
on Freshwater Inflow to Estuaries II:475-507.  U.S. Department of the
Interior, Washington, D.C. 
5. Rozengurt, M.A., M.J. Herz, and M. Josselyn.  1985.  In: D.L. Goodrich
(ed.) San Francisco Bay: issues, resources, status, and management.  NOAA
Estuary-of-the-Month Seminar Series No. 6.  (pp. 35-62)  NOAA,
Washington, D.C.
6. Rozengurt, M.A., M.J. Herz, and S. Feld.  1987a.  Analysis of the
Influence of Water Widrawals on Runoff to the Delta - San Francisco Bay
Ecosystem (1921 - 1987). Technical Report No. 87-7 (Library of Congress,
# 2 091 239)  Tiburon  Center for Environmental Studies, San Francisco
State University, Tiburon, CA.
7. Rozengurt, M.A., M.J. Herz, and S. Feld.  1987b.    The role of Water
Diversions in the Decline of Fisheries of the Delta - San Francisco Bay
and other Estuaries(1921-83).  Technical Report No. 87-7.  Center for
Environmental Studies, San Francisco State University, Tiburon, CA.
8. Rozengurt, M.A., and J.W. Hedgpeth.  1989.  The Impact of Altered
River Flow on the Ecosystem of the Caspian Sea.  Reviews in Aquatic
Sciences Vol. 1, 2, pp. 337-362.
Rozengurt, M.A.  1991.  Strategy and ecological and societal results of
extensive resources development in the South of the U.S.S.R.  In:
Proceedings, The Soviet Union in the Year 2010.  USAIA and Georgetown
University, Washington, D.C. 
9. Rozengurt, M.A. and I. Haydock.  1991.  Effects of fresh water
development and water pollution policies on the world's
river-delta-estuary-coastal zone ecosystems.  In: H.S. Bolton (ed.),
Coastal Wetlands Volume, Coastlines of the World.  (pp. 85-89)  Coastal
Zone '91, Proceedings of the Seventh Symposium on Coastal and Ocean
Management.  American Society of Civil Engineers, New York, NY.
10. Rozengurt, M.A.  1992.  Alteration of freshwater inflows.  In: R.H.
Stroud (ed.),  "Stemming the Tide of Coastal Fish Habitat Loss."  Marine
Recreational Fisheries Symposium 14:73-80.  National Coalition for Marine
Conservation, Savannah, GA.
11. Rozengurt, M.A. and I. Haydock.  1993.  The role of inland water
development on the systemic alteration of the coastal zone environment. 
In: Proceedings of Watershed '93, A National Conference on Watershed
Management.  U.S. EPA, Washington, D.C.
12. Rozengurt, M.A.  1994.  Running on Empty: the distortion of coastal
ecosystems.  In Proceedings of 7th Internationa Biennial Conference and
Coastal Seas: Buyoncy Effects on Coastal Dynamics.  Woods Hole
Oceanographic Institution. Woods Hole, MA USA.
13. Rozengurt, M.A. and J.W. Hedgpeth. 1997.  Distortion of thermodynamic
equilibrium of watershed - coastal seas' ecosystems. In Proceedings "
With Rivers to the Sea, Interaction of Land Activities, Fresh Water and
Enclosed Coastal Seas".  Joint Conference: 7th Stokholm Water Symposium
and 3rd International Conference on Enviromental Management of Enclosed
Seas (EMECS). 10 - 15 August. Stokholm, Sweden.
14. Simenstad, C.A., D.A. Jay and C.R. Sherwood.  1992.  Impacts of
watershed management on land-margin ecosystems: the Columbia River
Estuary.  In:  R.J. Naiman (ed.), Watershed Management, Balancing
Sustainability and Environmental Change.  (pp. 266-306)  Springer-Verlag,
NY.
Tolmazin, D.M.  1985.  Changing coastal oceanography of the Black Sea.
Prog. Oceanog. 15:217.
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Note: 1, 12, and 13 were added for the enclosed original text to
highlight the nature of discussion.

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