CSPA Files Complaint Against State Board, Bureau of Reclamation for Violations of Laws Protecting Sacramento River Chinook Salmon

The California Sportfishing Protection Alliance (CSPA) has filed a formal complaint against the State Water Resources Control Board (SWRCB) and United States Bureau of Reclamation (USBR) for violations of the Water Quality Control Plan for the Sacramento River and San Joaquin River Basins (Basin Plan), violations of WR Order 90-05 and Sacramento River temperature requirements and for violations of the Clean Water Act (CWA), Endangered Species Act (ESA), Public Trust Doctrine and the California Constitution.

Specifically, CSPA alleges that the SWRCB has failed to implement crucial Basin Plan water temperature criteria and CWA requirements protecting water quality and fish and wildlife beneficial uses with respect to USBR’s water rights permits and licenses and has failed to take enforcement actions against USBR’s habitual violations of the Basin Plan, CWA and WR Order 90-05 temperature criteria and requirements against USBR.  CSPA alleges that USBR has failed to comply with explicit temperature criteria protecting fish and wildlife beneficial uses contained in the Basin Plan, CWA and WR Order 90-05. CSPA additionally alleges that the SWRCB and USBR have failed to comply with their respective responsibilities and obligations under the ESA, Public Trust Doctrine and Article X of the California Constitution.

Should winter-run Chinook salmon, Delta and longfin smelt and potentially several other species that have evolved and thrived over millennia go extinct, it will not be because of drought. It will be because the SWRCB and USBR have refused to comply with the law.

CSPA Sacramento River Complaint

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CSPA Files Complaint Against SWRCB, USBR, DWR for Violations During Current Drought

On Tuesday, July 21 CSPA filed a complaint with the State Water Resources Control Board (SWRCB) against the SWRCB, US Bureau of Reclamation (USBR), and California Department of Water Resources (DWR) alleging a multitude of serious water quality violations during the current drought. The complaint alleges that in allowing these violations, these the agencies have violated the Bay-Delta Plan, D-1641 critically dry year water quality objectives, the Clean Water Act, the Endangered Species Act, the Public Trust Doctrine and the California Constitution.

Violations of Bay-Delta Plan and D-1641 requirements have resulted in increased salinity that has directly impacted multiple species, including American Shad, splittail, Chinook salmon, and the almost extinct Delta smelt. Despite growing consequences, the agencies have not provided any assurance of reasonable use of water. Agricultural practices like flood irrigation and the continued production of low value crops are allowed to continue while water standards are weakened to the point of ecological collapse.

Time and time, again the SWRCB has weakened and refused to enforce minimum standards during drought, and California’s fisheries and the public’s water security have paid dearly for these actions. Without an end to this drought in sight, the SWRCB must use its authority to enforce water quality standards and balance the public trust with competing uses.

CSPA Complaint

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CSPA Presentation on Sacramento Temperature Plan

On 24 June 2015, CSPA submitted a detailed presentation to the State Water Board’s workshop on drought issues, Delta flows and the revised Temperature Management Plan for the upper Sacramento River. Under the proposed plan temperature criteria would be increased from 56F to 58F at Clear Creek near Redding.

The failure to maintain adequate temperatures last year during spawning, incubation, emergence and early fry development led to the loss of 95% of winter-run, 98% fall-run and virtually all of the spring-run Chinook salmon brood year. It appears that a similar debacle is likely to occur this year.

In a joint press released issued with Restore the Delta, CSPA Executive Director Bill Jennings was quoted as saying, “Sacramento River water temperatures are already exceeding lethal levels and it’s beginning to look like this year will be a repeat of last years debacle that obliterated an entire brood year of Chinook salmon. Delta and longfin smelt are teetering on the precipice of extinction. And the State Water Board is again preparing to weaken legal water quality standards that are critical to the very existence of these species. It is both unreasonable, illegal and a moral sin to send species that thrived for millennia into extinction simply to provide millions of acre-feet of water to irrigate pasture, alfalfa and other low value crops in the desert.”

CSPA Waterboard Presentation

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CSPA Objects to Change in Delta Water Quality Standards

On 19 June 2015, CSPA, joined by the California Water Impact Network and AquAlliance, filed an extensive formal Objection to the 21 May 2015 Temporary Urgency Change Petition (TUCP Petition) from the U.S. Bureau of Reclamation (USBR) and California Department of Water Resources (DWR) asking the State Water Board to further weaken Bay-Delta water quality and flow standards established to protect fisheries and water quality. The State Board is expected to rule on the USBR/DWR TUCP Petition in the near future.

The Objection asks the State Water Board not to approve the TUCP Petition and its requested weakening of outflow requirements, relocation of the salinity compliance point to Threemile Slough and reduction in Sacramento River flow at Rio Vista between September through November.  If approved, these changes will cause the low salinity zone to move further east and expose Delta smelt and other pelagic species, already on the brink of extinction, to lethal water temperatures and harm Chinook salmon during critical migration periods.

The CSPA Objection describes the perilous conditions facing the Central Valley’s pelagic and anadromous fisheries, identifies the severe impacts that will occur if the requests are implemented, chronicles the egregious mismanagement by the state and federal water projects that have exacerbated the present drought crisis and identifies the numerous state and federal statutes that would be violated should the State Board approve the Petition. Should the State Board approval the Petition, the matter will be incorporated into CSPA’s recent lawsuit against the Board and USBR.

CSPA TUCP Objection

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CSPA Seeks to Protect Sacramento River from High Temperature and Toxic Metal Wastewater Discharges

In January 2013, CSPA filed a lawsuit against the Central Valley Regional Water Quality Control Board (Regional Board) for violations of the Clean Water Act in issuing a permit to the Sacramento Regional Sanitation District (SacRegional) for wastewater discharges to the Sacramento River. CSPA prevailed and, in October 2014, the Court ordered the Regional Board to 1) vacate the relaxation of compliance with the state’s Thermal Plan, 2) vacate portions of the permit that improperly established discharge limits for hardness dependent metals and establish new limits that comply with regulatory requirements and 3) establish a weekly effluent limitation for aluminum in the permit.

The permit regulates the discharge of up the 181 million gallons a day of treated municipal wastewater into a relatively narrow reach of the Sacramento River that is within the tidal prism and habitat and a migration corridor for numerous pelagic and anadromous fish species. Numerous species listed or proposed to be listed, pursuant to state and federal Endangered Species Acts, depend upon these waters for all or a critical part of their life cycle.

The Regional Board delayed complying with the Court’s order. CSPA returned to Court and secured an order directing the Regional Board to comply by 31 July 2015. The Regional Board subsequently issued a draft permit that evades complying with explicit regulatory requirements. CSPA submitted extensive comments on the draft permit on 19 June 2015, will be present at the Regional Board hearing on 30/30 July and should the Regional Board adopt the permit as drafted, CSPA intends to return to Court and request sanctions against the Regional Board.

CSPA Comment Letter

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CSPA Sues Department of Interior, Bureau of Reclamation, State Water Board and DWR to Prevent Fishery Extinctions

The California Sportfishing Protection Alliance, California Water Impact Network, AquAlliance and Restore the Delta have filed a complaint for declaratory and injunctive relief, under the Administrative Procedures Act, and a Petition for Writ of Mandate, under California Code of Civil Procedure, in federal District Court for the Eastern District of California.

The lawsuit alleges that the U. S. Department of Interior, U. S. Bureau of Reclamation the State Water Resources Control Board and the Department of Water Resources violated the federal Clean Water Act, the Bay-Delta Plan, Central Valley Project Improvement Act, the Delta Protection Act and other state and federal statutes in weakening and/or failing to comply with water quality standards established to protect the Bay-Delta estuary.  As a result of their failure to comply with the law, water quality in the Delta is severely degraded and fisheries have been pushed to the brink of extinction.

“We bring this lawsuit in an effort to prevent the impending extinction of fisheries that thrived for millennia. Delta smelt, once the most abundant species in the estuary, are on the precipice of extinction and longfin smelt and winter-run and spring-run Chinook salmon are close behind,” said CSPA Executive Director Bill Jennings adding “we cannot stand aside and watch species go extinct simply because special interests have captured our regulatory agencies and they refuse to comply with laws enacted to protect fish and water quality. The situation is critical and we’re left with no alternative but the courts. And we’re prepared to sue them again and again and again. We don’t know if we can save these species, perhaps we can, but by god we will try!”

Press Release   Lawsuit

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CSPA and allies comment on Draft EIS for Merced River relicensing

CSPA and seven other Conservation Groups filed comments on May 29, 2015 on the Draft Environmental Impact Statement for the relicensing of the Merced River Hydroelectric Project and the Merced Falls Hydroelectric Project. These relicensings began in 2009. The Federal Energy Regulatory Commission (FERC) issued the DEIS in March. Along with the State Water Board’s ongoing update of the Bay-Delta Water Quality Control Plan, these FERC relicensings will determine in part flows in the lower Merced River for the next 30-50 years.

The central theme of Conservation Groups’ comments is that the DEIS inequitably balances uses of the Merced River:

The Commission has an obligation to balance the beneficial uses of a waterway consistent with the public interest. Unfortunately, staff has adopted an overly restricted view of its authority to balance certain uses, leaving it with a self-inflicted inability to fix the institutional problem in the Merced River. That problem is unsustainable water demand, which systemically threatens the health of fish and wildlife resources that inhabit and utilize the Merced River, and which ultimately threatens the sustainability of the agricultural economy in eastern Merced County.

The comments conclude that, “… it appears that FERC is on course to leave the hard problems of this relicensing to others.”

Conservation Groups’ comments on Merced DEIS

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CSPA Comments on the Crisis in Delta at SWRCB

On May 20, 2015 the State Water Board held a workshop to hear comments on its April 6 Order that approved relaxed Delta flow and water quality standards until June. During the public comment period CSPA’s Bill Jennings presented yet again on catastrophic impacts weakening water quality standard has on the health of the Delta.

The presentation summarized the mismanagement by DWR and Bureau that has led to an estimated loss of 91% of Delta Smelt over the last three years, and devastating decline of 95% winter-run, 99% spring-run, and 97% fall-run Chinook salmon in 2014 alone. In contrast farming profits and jobs in both the Sacramento Valley and San-Joaquin Valley actually increased during the drought.

CSPA Presentation SWRCB – May 20 2015.PDF

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Support CSPA’s Actions to Enforce the Clean Water Act

CSPA is working with Lawyers for Clean Water, Inc. on a Clean Water Act enforcement action against an industrial facility near the Stanislaus River in Oakdale. Stormwater discharges from the dairy feed manufacturing and heavy equipment storage facility flow into the Stanislaus River, which conveys the pollutants to the San Joaquin River and then to the Sacramento-San Joaquin River Delta.

Downstream of FacilityUnder the citizen-suit provisions of the federal Clean Water Act, CSPA has issued a notice letter informing the owners of the facility of specific violations that CSPA has identified under the federal Clean Water Act and California’s General Industrial Stormwater Permit.

During this fourth year of drought, CSPA is working harder than ever. Please consider donating to the CrowdDefend campaign for this enforcement action. Your donation will support CSPA’s continued leadership in enforcing the Clean Water Act, and more importantly it will help to prevent the illegal pollution of California’s rivers.

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CSPA Protests Weakening Bay-Delta Flow and Water Quality Requirements

On May 6, 2015, CSPA, joined by CWIN, and AquAlliance, submitted a Protest, Objection and Petition for Reconsideration to the State Water Resources Control Board’s Temporary Urgency Change Order (TUCO) issued on April 6th. In the order the SWRCB continues to illegally fail to enforce water quality standards during the present drought.

This Protest follows CSPA’s February 13th Protest of the February 3rd TUCO,  presentations by CSPA at February 18th State Water Board workshop and  comments submitted to the Board on February 19th. With several fish species facing extinction, the Protest maintains that the weakened flow and water quality requirements proposed in the TUCO  will cause serious and, perhaps, irreparable harm to Delta fisheries and water quality.

CSPA Protest TUCP, Order, May 2015

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CSPA and very diverse partners working on salmon reintroduction to North Yuba River

The California Sportfishing Protection Alliance, Trout Unlimited and American Rivers, along with the California Department of Fish and Wildlife, National Marine Fisheries Service, and Yuba County Water Agency, released a framework on May 7, 2015, that will guide negotiations whose primary goal would be to reintroduce spring-run Chinook salmon (and possibly steelhead) into the North Yuba River upstream of New Bullards Bar Reservoir.

Working together as the Yuba Salmon Partnership Initiative (YSPI), these six entities have signed a “Term Sheet” and a have developed a “Concept Plan” that will guide further discussions on reintroduction. The settlement that the framework contemplates would, if completed, also define and implement physical habitat improvements in the lower Yuba River.

To be clear, this is not a “deal.” This is a preliminary setting of boundaries on what would be needed to reach an agreement. The Term Sheet and the settlement it contemplates do not propose to resolve all the issues in the watershed, including lower Yuba River flow or other issues that may arise in the FERC relicensing of YCWA’s Yuba River Development Project. What the YSPI proposes instead is to choose two areas where the parties are likely to find agreement and focus on those.

YCWA has argued that these two areas (reintroduction and lower river habitat improvements) are not within the purview of the Federal Energy Regulatory Commission, or of the State Water Board, since channel alteration and dam construction involve events, conditions and structures that predate YCWA’s hydroelectric project. CSPA and other conservation groups have argued (and we think very effectively) that both FERC and the State Board have jurisdiction. Rather than continue the argument in a drawn-out regulatory or legal context, we are trying to see if we can get an outcome that works for all the negotiating parties and for most other people, if not everyone, and especially that works for fish.

Some folks have asked why YSPI is going public now with the framework for an agreement, rather than waiting for an agreement itself. There are several reasons, but the most important is that we want to get it right. We therefore want to hear concerns, comments and above all suggestions from colleagues and supporters. We also want to hear from others who may have different concerns.

For many of us who have worked long hours for many years in the Yuba River watershed, the trap and haul program to the North Yuba that the YSPI contemplates is not what we envisioned when we started. Some will not find moving fish in trucks to be a good choice now, and some will never find it acceptable. After three years of review and analysis in the Yuba Salmon Forum, a process during which CSPA was showed up to almost every meeting, we believe trap and haul to the North Yuba is likely the best option that it is both technically and socially achievable and feasible, and we have committed to trying to work it through.

Please feel free to contact Chris Shutes at blancapaloma@msn.com if you wish to comment or if you have questions.

YSPI Term Sheet            YSPI Concept Plan               YSPI Project Summary                  FAQ

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The News is Spreading: California cannot continue to ‘save water’ by depleting flows to endangered fisheries

On the heels of mandatory urban water conservation requirements, the news is spreading that reduced delta inflows are not enough to support endangered delta fish populations. The articles below take a look at how California’s limited water supply is being shared, and begs the question: who are we conserving water for?

On April 20, 2015 the San Francisco Chronicle Open Form published Don’t ignore the San Francisco Bay’s needs during the drought.  In the article Gary Bobker, director of the Bay Institute, describes how “in order to save water over the last two years, the State Water Resources Control Board has virtually eliminated even the minimal bay inflows required under the Clean Water Act — which the state has acknowledged were already insufficient to protect the estuary.”  The apparent flaw is that the SWRCB is only ‘saving’ water for thirsty farms, not endangered delta species.

Comstock’s Groves & Fishes: There is water war brewing between farmers and fisherman was also published on April 20.  The article is a frustrating look at how many farmers vilify the native fish populations for not ‘sharing’ water. This is despite the fact that last fall so much water was ‘shared’, or rather taken, from endangered winter-run Chinook that “thousands of salmon were unable to spawn in the low and lethally warm water exiting Shasta Dam.”

The ChicoER succinctly sums up the situation in the Editorial: Little fish’s disappearance is a big problem, published on April 22, 2015. The article describes how those who see the Smelt as an obstacle for diverting more water from the Delta to the San Joaquin Valley are applauding the disappearance of the endangered fish. What these farmers and politicians choose to ignore is that the Smelt are only the beginning of problems for the Delta ecosystem: “If the Delta Smelt go, other species will be next.”

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Epidemic of Comprehension: Outbreak of articles on break-up of BDCP

Following news that the U.S. Fish and Wildlife Service will not issue 50-year environmental permits for the Bay Delta Conservation Plan (BDCP) an epidemic of comprehension has spread, resulting in an outbreak of articles on the break-up of BDCP.

On April 11, 2015 the San Jose Mercury News published Delta tunnels: Major changes to environmental restoration could endanger Brown’s water plan. In the article the Mercury News announced new information that “the Brown administration is proposing a major and politically risky change: dropping a 50-year guarantee to restore the Sacramento-San Joaquin River Delta’s environment.” Brown is quoted in the article saying the change is “kind of a technical point,” a sentiment not shared by others affected by the plan including an environmental group, farmers, and water agencies.

Published on April 17, 2015 the San Jose Mercury News editorial: Jerry Brown needs new water strategy — no tunnels acknowledges that without any conservation claim in the BDCP the project is… “Dead in the murky, barely habitable water.” Mercury staff urges Brown to use his leadership in ways other than promoting the tunnels.

Adding to the growing chorus the  The San Francisco Chronicle Editorials wrote The end of the delta tunnels plan? We should hope so on April 21, 2015.  In the editorial the Chronicle states “What we want to hear is how the state is prioritizing water for the environment and the San Francisco Bay-Delta estuary, not building tunnels to divert more of it to the south.”

Also on April 21 the Modesto Bee Editorial Board wrote Our View: Now we see real goal of Delta plan. Responding to the news that the BDCP is dropping the 50-year environmental permits the article points out that the co-equal goals of a reliable water source and environmental protections for the Delta “don’t mesh; they never have.”

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Five-Year Water Board Process Comes Up Short For Rivers during Historic Drought

The decision was a blow to Northern California waterways such as the Scott and Shasta Rivers, which suffer from extremely low to no flow, including during salmon spawning seasons. Above it a photo of the Scott River, taken in October 2014

The decision was a blow to Northern California waterways such as the Scott and Shasta Rivers, which suffer from extremely low to no flow, including during salmon spawning seasons. Above it a photo of the Scott River, taken in October 2014

On April 8, 2015, the State Water Resources Control Board rejected an urgent appeal of a coalition of conservation, tribal and fishing groups to formally recognize Northern California Rivers and Steads as “impaired” under the Clean Water Act. CSPA has been working with the group for years to get these waterways 303(d) listed under the Clean Water Act due to over-diversion that has resulted in flows too low to support fish and other uses. Numerous other states already identify waterways as “impaired” due to low flow and are acting on that identification to put more water back into waterways, but the State Water Board has chosen to dismiss this important opportunity.

Coalition Media Release

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CSPA Continues the Fight with Central Valley Regional Board for Immediate Water Quality Compliance

The California Sportfishing Protection Alliance (CSPA) has won a motion to ensure prompt compliance with a writ issued against the Central Valley Regional Water Quality Control Board (Regional Board) regarding the wastewater discharge permit for the Sacramento Regional Wastewater Treatment Plant. In October 2014, the Honorable Michael P. Kenny of the Sacramento Superior Court found that the Regional Board had abused its discretion in developing the permit and ordered immediate changes to the permit. When the Regional Board filed a response in December 2014 indicating that it would not begin complying with the writ until December 15, 2015, CSPA challenged the Regional Board’s delay. On March 26, 2015, the Court ruled that the Regional Board had delayed compliance with the Court’s order, which requires immediate compliance. The Court noted that the Board’s delay, driven by solely by convenience, and was “not acceptable” and ordered the Board to comply with the Order no later than July 31, 2015. The Court will retain jurisdiction to ensure compliance.

Final Order On Objections to Writ

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CSPA supports cold water for NF Feather River and protections for Lake Almanor

CSPA and American Whitewater (AW) filed joint comments March 26, 2015 on the Draft Environmental Impact Report (DEIR) for the Water Quality Certification for relicensing of the Upper North Fork Feather Project. The State Water Resources Control Board issued the DEIR in November, 2014, about ten years after the relicensing process concluded.

The comments identify water temperature in the NF Feather River as the “the single greatest aquatic issue still facing the North Fork Feather River from Lake Almanor to Oroville Reservoir.” PG&E’s hydroelectric project warms the temperatures in the river by routing water through Butt Valley Reservoir, to the south and east of Lake Almanor, before the water is funneled back to the river at Belden Forebay. CSPA and AW recommend releasing more water directly from Lake Almanor into the river during the summer in order to keep water temperatures down in July and August, avoiding the bypass that causes too much warming. The trout fishery in the NF Feather, though partly improved by an agreement reached in 2000, is still a shadow of its former greatness. A supporting economic analysis to the comments cites the potential value of a restored river fishery as being in the millions of dollars annually.

Many people in Plumas County are concerned that releasing more cold water into the river will reduce cold water habitat for fish in Lake Almanor. CSPA and AW share that concern, and oppose the “thermal curtain” approach highlighted in the DEIR. Instead, CSPA and AW propose improving dissolved oxygen Lake Almanor near its dam, where there is ample cold water but where most of the cold water has too little dissolved oxygen to support fish. CSPA and AW cite “oxygenation” facilities used in Camanche Reservoir by East Bay MUD as a proven and cost-effective technology for improving conditions in the lake. By making more of the cold water in Lake Almanor usable for fish, there can be sufficient water to restore the cold water conditions of the NF Feather and substantial improvements for the Lake Almanor trout fishery at the same time.

CSPA and AW call for the State Board to release additional technical data as soon as possible, and to recirculate or supplement the DEIR after correcting the document’s errors. In the meantime, CSPA and AW will engage multiple stakeholders to seek resolution of differences in approach to the problems of Lake Almanor and the North Fork Feather River.

CSPA AW comments Upper North Fork Feather DEIR

ECONorthwest comments economic value of restored river

Wales and Hansen Report on North Fork Feather fishery in 1952

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Fishermen, Delta Leaders: Exporters “Destroy Delta Smelt”

The California Sportfishing Protection Alliance (CSPA) and Restore the Delta issued a press release on Tuesday, March 17, 2015 documenting how State and federal fish agencies are failing to enforce laws to protect fisheries. Simply put, if endangered species become extinct, fault will be with State Water Board and captive fish agencies.

Bill Jennings, the executive director of the California Sportfishing Protection Alliance, explains the severity of the mismanagement: “The State Water Board, even in the face of near-extinction of Delta smelt and salmon, is proposing to drastically relax minimal water quality and flow standards enacted to protect the Bay-Delta and tributary streams, for the third year in a row. Delta and longfin smelt and Winter-run salmon have collapsed to less than one percent of historic numbers, and are facing extinction. Yet the Water Board and the Governor expect our rivers and fisheries to bear the burden and suffer the consequences of mismanagement, even as additional acres of almonds are planted in the Valley. The Delta is a national treasure belonging to all of the people in the state and nation. It must not be sacrificed to the insatiable greed of special interests,”

Press Release: Export Projects Overpumping Delta During Drought Destroys Fisheries 

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CSPA Follows up at State Water Board on Economics, Fisheries and Water Deliveries

February 26, 2015 – In a supplementary filing to the State Water Board, CSPA submitted supporting information in opposition to weakening Delta flow and water quality standards as requested by the Department of Water Resources and the Bureau of Reclamation on January 27.  CSPA submitted records showing increases in San Joaquin Valley farm production and income even during times of drought.

In addition to the comments CSPA also submitted one letter rebutting claims by DWR and the Bureau that reduced standards won’t harm fish, and a second letter showing how water that is supposed to be saved by reducing Delta standards can easily benefit irrigation deliveries without improving any conditions for fish. Read more in the documents, shared below:

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CSPA Back before the State Water Board

Bill Jennings, Tom Cannon, and Chris Shutes pack pack into the crowded Water Board Meeting.

Bill Jennings, Tom Cannon, and Chris Shutes pack into the crowded Water Board Meeting. Photo Credit: Dan Bacher

February 18, 2015.  The State Water Board held a workshop on February 18, 2015 to hear comments on its February 3 Order that relaxed Delta flow and water quality standards in the Delta.  The Department of Water Resources, Bureau of Reclamation, and various other water agencies argued for increasing Delta exports even during times of low Delta inflow and outflow.  In opposition, CSPA made three presentations.  Tom Cannon discussed impacts of weakened standards on salmon and smelt in the Delta.  Chris Shutes discussed unreasonable effects on fish and wildlife in the Sacramento River and the importance of making water transfers comply with Delta standards.  Bill Jennings summed up by recounting the decline of fisheries over the past thirty years and the results of failure by the Board to enforce standards in dry years, when those standards are already too weak.  Comparing the operators of the state and federal projects to Goldman Sachs (sellers of unbacked securities), Jennings called on the Board to hold a hearing on Delta standards during drought and to create a legacy of protecting the public trust.

View Presentations from CSPA:

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CSPA Opposes Weakening of Delta Standards

February 13, 2015.  The State Water Project and Central Valley Project have doubled down on last year’s disastrous rollback of Delta flow and water quality standards. The Department of Water Resources and the Bureau of Reclamation, operators of the state and federal projects, submitted a Temporary Urgency Change Petition to the State Water Board on January 27, 2015. On February 3, 2015, the State Water Board granted the same reductions in Delta standards that it granted during last year’s drought conditions, but denied a request that would have allowed additional south Delta pumping under conditions of reduced Delta outflow.

On February 13, CSPA filed an Objection, Petition for Reconsideration, and Petition for Hearing in opposition to the Change Petition and Change Order. The filing describes record low numbers of Delta smelt and the loss of salmon in the Sacramento River that occurred as a result of last year’s reduction of Delta standards. Included with the Objection are a series of documents that demonstrate the decline of Delta fisheries over the past several years. In the short term, CSPA advocates for a simple action: maintain Delta standards during the drought.

CSPA et al Protest, Objection Petition

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