In addition to failing to rectify years of water quality violations in the San Joaquin River and South Delta, the proposed plan also fails to increase flows sufficiently to restore salmon and steelhead in the San Joaquin River. It fails to balance the public trust. It fails to provide sufficient water quality and water quantity to protect and enhance South Delta agriculture as mandated in the Delta Reform Act of 2009.
And it fails to protect all parties equally dependent on the health of the San Joaquin River, by giving priority status and protection to upstream users — all at the expense of water users on the lower San Joaquin River, Delta farmers, Delta residents, and Delta fisheries.
The Sacramento-San Joaquin Delta estuary cannot be restored without the San Joaquin River’s restoration. The SED selection of only 35% of unimpaired flows during February through June for the three main tributaries to the Lower San Joaquin River will not preserve and protect public trust values including fish, wildlife, and recreation.
We understand and empathize with the water users on the lower tributaries who have senior water rights. We heard from a number of them yesterday at the hearing. Their solution, however, is that the Delta should not receive any additional water. It seems to us that the water users on these tributaries should be demanding to know why aren’t the water users upstream being asked to put water back into the system? Why is the San Joaquin River being segmented in this plan?
The plan clearly prioritizes no net loss to water exports, or maintaining the water yield for Central Valley and State Water Project water takers, over all beneficial Delta uses, and more senior water right diverters on the Merced, Tuolomne, and Stanislaus Rivers. It is clear that the Board staff has ignored its responsibility to evaluate and balance competing water needs in developing flow and water quality objectives.
In its concern to protect a specific group of powerful corporate agricultural interests through this plan, it is clear that the State Water Resources Control Board has forgotten about a sizeable area of the Delta agricultural economy that is dependent directly on water quality and quantity from the San Joaquin River. In addition, the Delta recreation economy, valued at over $650,000,000 annually – in addition to the coastal commercial salmon fishery, which is valued at $1 to $2 billion annually –is dependent on the protection and restoration of the San Joaquin River and adequate flows into the Delta.
As it stands now, this plan and its SED, which will allow for the continuation of dewatering the Delta for years to come, ensures a permanent drought for the San Joaquin River, the estuary, the San Francisco Bay, and the economies that depend on the health of this ecosystem. Thus, it fails as a planning document to protect the interests of the people of the Delta, the people of California, and the environment.
It also gives us great pause. Just imagine how flow standards will be set for the Sacramento River if the twin tunnels are brought into operation? We have survived years of continual assault on one of our major rivers – but with great difficulty. A second assault on Sacramento River flows will result in the death of the Delta.