Joint Comments on Bay-Delta Plan Amendments for Flow Objectives on Lower San Joaquin River

  • Jul 27, 2018
  • Comment Letters

Agency: State Water Resources Control Board

Subject: Bay-Delta Plan Amendments for Flow Objectives on Lower San Joaquin River

Letter excerpt:

The organizations listed below urge the Board to reject the proposed amendments to the
Water Quality Control Plan for the San Francisco Bay/Sacramento-San Joaquin Delta Estuary relating to new and revised flow objectives for the Lower San Joaquin River and its tributaries – the Stanislaus, Tuolumne, and Merced Rivers – and the supporting proposed final Substitute Environmental Document (respectively, the “Flow Criteria” and the “SED”). Instead, the Board should direct its staff to engage the numerous stakeholders throughout the affected region in a renewed, vigorous, and realistic effort at voluntary settlement agreements that are intended to reconcile fish and wildlife objectives with the long-established and marvelously productive landscape of human water use and settlement on those rivers. In most cases, the undersigned organizations have already commented on the proposed Flow Criteria and the SED in its earlier draft rounds, from which the current proposed final documents depart little; the comments below are intended to underscore for the Board the magnitude of human impacts the Flow Criteria may have, to reiterate the legal issues which we believe the Board will have to defend if it adopts these documents, and to remind the Board that alternative pathways still exist for the achievement of
fish and wildlife goals.

I. IMPACTS

The Board’s Lower San Joaquin River proposal is only the initial phase of a multi-phase
process that would ultimately target even greater flows from the Sacramento Valley and Eastern Delta, yet the impact of the Flow Criteria alone would itself be large and unprecedented. By the SED’s own reckoning, 30- to 50-percent unimpaired standards on the three tributaries would reduce surface water diversions in the three affected watersheds by an average of 180,000 to 490,000 acre-feet a year, and up to 900,000 acre-feet in dry years.

Download joint comment letter

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