Russian River Frost Protection

Water Demand Management Program FAQs

After March 14, 2015, except for diversions above Warm Springs Dam in Sonoma County and Coyote Dam in Mendocino County, any diversion of water from the Russian River stream system, including the pumping of hydraulically connected groundwater, for purposes of frost protection from March 15 through May 15 shall be diverted in accordance with a board approved water demand management program (WDMP).

This page is intended to answer common questions regarding the requirements of the regulation. To fully understand the regulation, read the regulation and the resolution adopting the regulation.

Why is a frost protection regulation necessary on the Russian River?
Frost protection of crops is a beneficial use of water. But during a frost the high simultaneous demand for water for frost protection by many growers can lower stream levels in a way that fish become stranded and die. Stranding mortality of salmonids can be avoided by coordinating frost diversion practices between growers. Stranding mortality of salmonids can be avoided by managing frost diversion rates between growers.
Does the regulation apply to the entire Russian River stream system?
Diversions upstream of Warm Springs Dam in Sonoma County or upstream of Coyote Dam in Mendocino County are exempt from the Frost Protection Regulation.
Why are growers upstream of the dams exempt from the regulation?
The purpose of the regulation is to protect salmonids from stranding mortality. Salmonids do not have access to the Russian River stream system above these two dams.
Do I have to be part of a Water Demand Management Program (WDMP)?
If you answer “yes” to all of the following, you have to be part of a WDMP:
1. Do you divert surface or groundwater from the Russian River stream system anytime between March 15 through May 15?
2. Is your diversion point downstream of Warm Springs Dam or Coyote Dam?
3. Do you divert water for the purpose of frost protection?
What exactly is a WDMP?
A water demand management program (WDMP) is basically a locally-run coordination effort among neighboring growers to manage frost water demand in a manner that prevents a sudden large drop in the water levels of the river or its tributaries. The basic components of a plan are:
1. An inventory of frost diversion systems in the area of the WDMP.
2. A stream stage monitoring program.
3. Risk assessment of stranding mortality due to frost diversions.
4. Identification and timelines for corrective action implementation, if any.
5. Annual reporting of program data, activities and results.
When do WDMPs need to be submitted to the Water Board?
The due date is February 1, 2015. The following elements must be submitted at that time for a WDMP to be approved:
1. Identity of the individual or governing body in charge of the WDMP.
2. Names of participating diverter(s).
3. Source of water and acreage frost protected.
4. Schedule for completing the frost inventory, developing and implementing the stream stage monitoring program, and conducting the risk assessment. This schedule must be created after consultation with the California Department of Fish and Wildlife and The Nation Marine Fisheries Service regarding the stream stage monitoring program and risk assessment.
What, or who, can be a "governing body?"
Participating growers can choose who manages their WDMP(s). The governing body may be an individual, consulting firm or governmental entity capable of administering the WDMP. While growers can submit and manage their own WDMP individually, coordination among growers will be a necessity for adequate risk assessment. Collaboration among multiple growers will distribute the associated costs and personal time required to develop and implement the WDMP.
How much money does a WDMP cost?
There is no filing fee to submit a WDMP, however there will be costs associated with the development of the program and the eventual purchase of streamflow gages. In general, the costs to those who participate in a WDMP that covers multiple diverters will be lower than for those who submit an individual WDMP. The total cost of complying with the procedural aspects of the regulation can easily be shared without compromising the effectiveness of the WDMP. Diverters who manage their own WDMP will be solely responsible for the entire cost of their compliance with the regulation.
Can I join an approved WDMP after February 1, 2015?
Yes. Late membership/participation in already-approved WDMPs must be confirmed by the governing body and communicated to the State Water Board before March 15, so you should join one as soon as possible.
What if I plan to participate in a WDMP that is not submitted by February 1, 2015?
The Deputy Director will continue to process and approve WDMPs submitted after February 1, 2015, but there is no guarantee that late-submitted WDMPs will be approved prior to the first frost event of the 2015 frost season. Accordingly, if you are not participating in a submitted/approved WDMP by February 1, 2015, you should immediately join one in your area. The Board will maintain a list of approved WDMPs on its Website.
Are examples of WDMPs available?
Yes, submitted WDMPs and responses from the Water Board are available on our Website.
I pump non-hydraulically connected groundwater for frost protection purposes. Do I need to be part of a WDMP?
Yes, at least initially. You and/or the governing body of your WDMP may develop and submit criteria to the State Water Board for identifying groundwater diversions that are not hydraulically connected to the Russian River stream system. Once the criteria are approved by the Deputy Director for Water Rights, they may be used, together with stream monitoring data or other evidence, to support a determination that your diversion qualifies for an exemption. Individual diverters may request an exemption to the regulation. However, the process outlined above (approved criteria for showing that the groundwater diversion is not hydraulically connected coupled with stream monitoring or other evidence) is required for any exemption.

Diversions of groundwater for frost protection from the Russian River stream system, below Warm Springs Dam in Sonoma County and below Coyote Dam in Mendocino County, between March 15 and May 15 are not exempted from the Regulation until an affirmative determination has been made by the Deputy Director that the diversion is not hydraulically connected to the surface stream system.
I use a pond that collects sheet flow as a water source for frost protection. Do I need to be part of a WDMP?
If you divert any water from the Russian River stream system, including the pumping of hydraulically connected groundwater, for purposes of frost protection from March 15 through May 15, you must be covered under an approved WDMP. The Deputy Director for Water Rights will consider any evidence that you submit supporting a claim that the sole source of water to frost protect is from diffused surface water from precipitation. Until Division staff can confirm that your frost protection operation does not involve the diversion of water from the Russian River stream system you should strongly consider diverting water in accordance with a Board-approved WDMP to ensure that your frost protection diversions are not unreasonable.
If, under the terms of my water right, I store water in an off stream pond prior to March 15^th, and I do not divert any additional water to storage or from other sources for the purposes of frost protection, is my diversion subject to the regulation?
Diversions occurring prior to March 15th are not subject to the regulation. However, diversions to refill a reservoir after a frost event between March 15th and May 15th (including groundwater diversions from hydraulically connected sources) are subject to the regulation, and must be done in accordance with an approved WDMP.
If the water I use for frost protection is obtained solely from the Redwood Valley County Water District (District) is my diversion subject to the regulation?
The District obtains water from Lake Mendocino above Coyote Dam. Use of water purchased from the District is subject to the regulation if both of the following are true:
1. The water is conveyed to your point of diversion in a stream channel that is part of the Russian River stream system, including all tributaries to West Fork Russian River; and
2. The stream channel is not located upstream of Coyote Dam.
The diversion is not subject to the regulation if the water is delivered to you in a pipe or ditch which is not hydraulically connected to the Russian River stream system and all water comes from the sources above Coyote Dam.
If I do not use water for frost protection, but I use water for irrigation between March 15 and May 15, do I have to participate in a WDMP?
No.
If there are fish barriers on the stream where my diversion is located preventing fish from migrating upstream, will I still have to develop a monitoring plan and minimum stream stage for the WDMP?
Yes. If your diversion is subject to the regulation, it must be in accordance with an approved WDMP. The extent of the impact your diversion has on downstream stream stages will be determined and addressed in the later phases of the WDMP implementation.
What is the address that the WDMP materials need to be sent to*?

State Water Resources Control Board
Russian River Frost Regulation
Attention Lee Barclay
P.O. Box 2000
Sacramento, CA 95812-2000

*Certified Mail can be delivered to this PO Box.

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