CSPA filed extensive comments March 17, 2017 on the State Water Board’s plan for improving flows in the lower San Joaquin River and for allowing more salinity in the southern Delta during the growing season.
CSPA supports the Board’s approach of requiring the release of a percent of unimpaired flow in February-June in the Stanislaus, Tuolumne and Merced rivers. However, CSPA thinks the Board’s plan as stated will not keep enough water in rivers to restore fisheries. The percent-of-unimpaired flow approach is universally opposed by San Joaquin River water users because they divert too much water and don’t want to give it back. CSPA thinks of it as being like a person whose kidneys are failing due to blood loss: you can treat the kidneys alone in the blood-starved body (the water users call this “functional flows”) or you can put enough blood back in the system for it to heal itself.
CSPA opposes weakening the salinity standard.
Unfortunately, there are many defects in the Board’s plan as described in its “Substitute Environmental Document” or SED. CSPA describes many of these flaws, including failure to clearly define the proposed project, modeling that doesn’t line up with what the Board actually proposes to do, and an “adaptive implementation” program that pushes key decisions to other people in the future. CSPA recommends that the Board redo its modeling and analysis comparing variable values for flows, carryover reservoir storage, diversion allocations, water temperature targets, levels of south Delta exports by the state and federal water projects, level of contribution to flows by the City of San Francisco, and specific plans for droughts.
As an attachment to CSPA’s comments, biologist Tom Cannon provided recommendations for temperature targets in the lower San Joaquin River and its tributaries.