Dear Chairwoman Felicia Marcus:
The State Water Resources Control Board is slated for a Nov. 7 vote on a Bay-Delta Water Quality Plan which would require 40 percent of unimpaired flows to remain in the rivers to purportedly revive chinook salmon through the Sacramento-San Joaquin Delta.
If the Board adopts the proposed Plan, it is with little to no regard for the impacts on the ecosystem of mountain counties and impacts on endangered aquatic plant and animal species, including endemic and migrating species that are already stressed by forest fires and drought. The board’s plan will penalize rural disadvantaged communities in California’s 16 mountain counties, increase fire-prone vegetation, exacerbate tree mortality, increase the risk of catastrophic fire in the Wildland Urban Interface, degrade air quality, increase ground temperature and further degrade the overall health of the Sierra Nevada environment.
The unimpaired flow regime is a “take” from the California tributaries and a failure to understand the value of this water being kept in circulation in the mountain counties region. As you know, the state has a highly altered watershed with dams and diversions, and a highly altered Delta waterway that includes dozens of islands and 1,000 miles of levees and diversions that will never return to pre-anthropogenic influence. Use of this unimpaired methodology to determine water flow in the tributaries is flawed.
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The SWRCB should abandon this concept.
Still missing from the discussion is the science developed by the Delta Independent Science Board. In 2015, the ISB reported “flow is but one factor affecting fishes and its effects are confounded by other drivers of fish production in the ecosystem.”
The report noted, “it is almost impossible to assess how flows affected fishes historically in the Delta because the ecosystem has undergone and is still experiencing dramatic alterations in habitat, species composition and interactions, channel morphology, and water quality.”
This research validates arguments against using an unimpaired-flow methodology.
Further, “much research in the Delta has been understandably focused on endangered or threatened species and some non-natives such as the striped bass. These non-native species dominate fish biomass in much of the Delta and have disrupted historic food webs. Ecologically important species of fish are those that dominate the ecosystem and/or play key roles in the food web.”
The report stressed: “Little is known about the impact of flows on many of these species and they likely have important food-web relationships to threatened or endangered species.”
A more effective plan to achieve desired results is to:
▪ Implement the ISB’s science-based approaches recommended by Peter Moyle, Ph.D.; Doug Demko, president of FishBio and others.
▪ Entertain and accept voluntary settlement agreements developed in cooperation with the Natural Resources Agency.
▪ Establish an effective pulse-flow standard to preserve water for fish when and where they need it.
These steps should be considered and implemented if the state is to bolster the salmon population in tributaries of the San Joaquin River.
We all recognize the water board is faced with tough and complex decisions. However, the imposition of minimum in-stream flows done in the name of protecting fish should not be done at the expense of people’s right to reliable water supplies. While the water board might have an obligation apart from the California Department of Fish & Wildlife to protect fish from harm, the California Legislature has made it clear the people of California have a right to reliable water supplies as stated in the Delta Plan’s “Co-Equal Goals” – which you played an integral role in developing.
I respectfully request you put off the Nov. 7 vote, study the unintended consequences to the mountain counties region, and implement the above-mentioned steps to help achieve long-term water reliability for people, fish, agriculture and the environment.
John Kingsbury is executive director Mountain Counties Water Resources Association. This letter was sent to state water board chairwoman Felicia Marcus and copied to 19 elected and appointed federal and state officials.