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Another Drought Year, Another Temporary Urgency Change Petition to Weaken Delta Water Quality Standards

The Bureau of Reclamation and California Department of Water Resources (DWR) have proposed another temporary urgency change petition (TUCP) for Delta operations in 2022 (Figure 1, below).  The purported purpose is:

operating the Projects to provide for minimum health and safety supplies…; preserve upstream storage for release later in the summer to control saltwater intrusion into the Sacramento-San Joaquin Delta (Delta); preserve cold water in Shasta Lake and other reservoirs to maintain cool river temperatures for various runs of Chinook salmon; maintain protections for State and federally endangered and threatened species and other fish and wildlife resources; and meet other critical water supply needs.  (TUCP, p. 1).

Under the previous TUCPs in 2014, 2015, and 2021, Reclamation and DWR did not preserve reservoir storage, control salt water intrusion, maintain cold-water in Central Valley reservoirs, or protect listed fish species, but they sure did sustain Central Valley farmers.  In the spirit of being consistent, the latest TUCP makes no mention of the tradeoffs or specific priority criteria.  That’s because, once again, everything in this TUCP is for water contractors.  There is no fresh water to the Bay, its crabs, herring, or anchovies, let alone its salmon, smelt, striped bass, or other fisheries.

The TUCP claims: “The TUCP will support Reclamation and DWR in balancing the competing demands on water supply and is critical to provide some protection of all beneficial uses of the Delta including for fish and wildlife, salinity control, and critical water supply needs.”  (TUCP, Environmental Information, p. 1).  No, it’s simply for contractor water, nothing else.

The TUCP explains: “The continuation of extremely dry conditions in the Delta watershed has resulted in inadequate water supply to meet water right permit obligations for instream flows and water quality under D-1641.”  (TUCP, p. 1).  Apparently, Reclamation and DWR must have forgotten that during extremely dry conditions last year and the year before, Reclamation and DWR gave too much water to their contractors.  They depleted storage to historic lows.  In 2020 and 2021, they knew the snowpack was low.  They knew reservoirs would empty.  They delivered the water anyway.

Well, things are looking really bad: “[T]he conditions of 2021 have left the Projects in a precarious state, with little water to manage even under slight drought conditions next year.”  (TUCP, p. 2).  They knew this was going to happen.  They also knew they could employ their TUCP tricks again.

But fear not.  “[T]he proposed changes in operations will not injure other lawful users of water; will not unreasonably affect public trust resources such as fish and wildlife or other instream beneficial uses; and are in the public interest.”  (TUCP, p. 2).  This is an outright lie, and they think we are suckers enough to believe it.

Figure 1. TUCP Framework, Table from TUCP, p. 2.

Translation of Figure 1: Let no water flow to the Bay.  Open the Delta Cross Channel gates to capture all the out-migrating salmon, steelhead, sturgeon, and steelhead and divert them straight to the Central Delta and water project pumps, along with the fresh water from the Sacramento River.  Let the San Joaquin River die.  Make minimal exports from the Delta because upstream contractors will take all the reservoir and river inputs to the Delta.  Well, not entirely, because upstream contractors will sell much of their water to Southern California users.  The State Water Board will allow transfers through the Delta without the minimal safeguards required for non-transfer exports.  In sum, Reclamation and DWR will deliver to Sacramento Valley contractors about 20 times the water allegedly “saved” by weakening Delta standards, once again disproving the elementary school arithmetic that says to preserve storage, you can’t let more water out of a reservoir than you take in.

Is this a great system or what?

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