ACWA Comments on Revisions to Proposed Bay-Delta Plan Amendments

  • Jul 27, 2018
  • Comment Letters

Agency: State Water Resources Control Board

Subject: Revisions to Proposed Bay-Delta Plan Amendments

Letter excerpt:

The Association of California Water Agencies (“ACWA”) appreciates the opportunity to comment on the State Water Resources Control Board’s (“State Water Board’s”) proposed amendments to the Water Quality Control Plan for the San Francisco Bay/Sacramento- San Joaquin Delta Estuary (the “Bay-Delta Plan”) and final Substitute Environmental Document (“SED”). ACWA is a statewide association that represents more than 445 public water agency members that collectively supply approximately 90 percent of the water that is delivered for agricultural, municipal and industrial uses in California. ACWA strongly believes that the policy of coequal goals set forth in state law and emphasized in the California Water Action Plan has the potential to put California on a path that includes both a vibrant agricultural and urban economy and a healthy ecosystem. However, the State Water Board’s proposed approach in the Bay-Delta Plan is inconsistent with the coequal goals of improving water supply reliability and enhancing the Delta ecosystem established in the Delta Reform Act of 2009. By reducing available surface water supplies and triggering increased groundwater pumping, the approach works against the goals of the Sustainable Groundwater Management Act (“SGMA”). The proposed approach would additionally undermine the implementation of the California Water Action Plan, particularly in the areas of improving water supply reliability, sustainably managing groundwater, and providing safe drinking water for all communities.

ACWA has been actively engaged on the State Water Board’s efforts to update to the Bay-Delta Plan. On March 10, 2017 ACWA’s Board of Directors unanimously adopted the attached policy statement on the Bay-Delta Plan’s requirements, which is incorporated into the following comments. On March 17, 2017, ACWA submitted comments to the State Water Board on the draft revised Bay-Delta Plan amendment urging for comprehensive, collaborative approaches that includes functional flows as well as non-flow solutions that contribute to real benefits to ecosystem recovery.

Download joint comment letter

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