CSPA joined the California Water Impact Network, AquAlliance, Friends of the River and Restore the Delta in submitting extensive comments on the State Water Resource Control Boards Substitute Environmental Document for Phase I of the update of Water Quality Control Plan for the Delta. Phase I addresses flows in the San Joaquin River and South Delta salinity standards.
The comment letter identifies violations of the federal Clean Water Act, Porter-Cologne Water Quality Control Act, the Delta Reform Act of 2009, the California Environmental Quality Act and the Public Trust Doctrine. CSPA had previously testified and presented expert testimony in the Phase 1 and Phase II workshops that were incorporated into the record. A workshop on the proposed changes to the Bay-Delta Plan and draft SED was conducted earlier in March.