Since 2009, representatives of the City and County of San Francisco have consistently advocated against flow increases in the lower Tuolumne River. In proceedings before the Federal Energy Regulatory Commission and the State Water Board, San Francisco’s advocates have argued that increased flow will cause economic disaster during dry year sequences. The general strategy of the City’s attorneys, staff and consultants has been to make a bunch of assumptions about dry year water supply and demand and rationing, and then to have a few experts describe in vivid detail what would happen if those assumptions were true. Then they argue that since increased flow can’t work in droughts, there’s just nothing to do.
On July 29, 2014, San Francisco’s City Attorney sent a letter to staff at the State Water Board with a new version of the same tired arguments. The immediate issue was how the State Water Board will evaluate impacts to the City in an environmental analysis of changes to flow in tributaries of the San Joaquin River, including the Tuolumne. A copy of the letter was filed with FERC.
On October 8, 2014, ten conservation groups who’ve been working in FERC proceedings on the Tuolumne River, including CSPA, filed a response to the City’s letter with both the State Water Board and with FERC. The conservation groups’ response provides background about the City’s advocacy over the last five years and makes numerous suggestions about different ways the City might comply with increased flow requirements or mitigate their impacts to the City’s water supply and economy. These include creating different flow requirements during multiple dry years and expanding efforts (some of which are already underway) to secure alternative supplies if Tuolumne River supplies run short.
One of the few positive things about the current drought is that it has shown that people, especially in the Bay Area, value water conservation and are willing to work at it. Bay Area water agencies are talking to each other about sharing resources and infrastructure, particularly during drought situations. Agricultural demand reduction by other users of Tuolumne River water is also going to have to be part of the solution.
The San Francisco Board of Supervisors passed a resolution on July 22, 2014 stating that the “… San Francisco Bay-Delta Estuary helps to power [the Bay Area’s] economic engines, is the globally recognized symbol of our region, and its health reflects on our region’s capacities, values and vibrancy . . . .” San Francisco needs to line up its water supply policies with its values. The most progressive City in the world can and must do better than just say no.
Conservation Groups’ October 8, 2014 Response to City and County of San Francisco