Comments on Potential Amendments to Bay-Delta Plan Phase II Update Dec 16, 2016 Comment Letters Agency: State Water Resources Control Board Subject: ACWA Comments on Working Draft Scientific Basis Report for Potential Amendments to the Bay-Delta Plan Phase II Update Letter excerpt: ACWA believes that a life cycle approach that relies on a comprehensive set of tools to better manage aquatic resources is the appropriate path forward in implementation of laws that are designed to protect ecosystems. Focusing on “unimpaired flows” without addressing the myriad other factors affecting aquatic species populations and habitat has served to maximize conflict between species protection and water supply while failing to adequately serve either. ACWA appreciates the comments of Water Board members at the December 7th workshop that a new concept of a “block of water” that is used for various projects that improve habitat conditions and are timed appropriately to provide the maximum benefit to species in the system could be a preferred approach, similar to the “functional flows” concept advanced by the Sacramento Valley Water Users. This concept should be developed using all available science, including key reports that were highlighted by the Sacramento Valley Water Users group at the December 7th workshop. ACWA cautions against proceeding with scientific analysis of any flow approach that would promote further increasing “unimpaired” in-stream or Delta outflows when such flows would not naturally occur in the system, or when such flows are infeasible given the operational constraints of the existing water supply system. The best available science does not support such an approach, especially given the resulting impacts on California’s water supply and economy. As has been underscored in recent drought years, all of California’s water resources must be used in an effective manner that will both improve ecosystems and continue to support other identified beneficial uses. ACWA looks forward to continuing to engage with the SWRCB throughout the process of the Bay-Delta Plan update. Download ACWA’s comment letter