Bay Delta Plan Update: Comment on Final SED

On July 6, 2018, the State Water Board released a final proposal to amend the Bay Delta Water Quality Control Plan (Proposed Final Amendments) and a Final Substitute Environmental Document (SED) for the Lower San Joaquin River and Southern Delta. To review these documents visit the State Water Board’s website. Comments are due before 12pm Noon on July 27, 2018. See instructions for submitting comments below (scroll down for talking points):

  • Email Jeanine Townsend, Clerk to the Board, by email at LSJR-SD-Comments@waterboards.ca.gov (please note that the email capacity is less than 50 megabytes total). Please title the subject line: “Comment Letter – Revisions to Proposed Bay-Delta Plan Amendments.” Electronic submission by email in pdf text format is preferred.
  • Attend the State Water Board meeting and give oral public comments on Tuesday, August 21, 2018, 9:30 a.m. and/or Wednesday, August 22, 2018, 9:30 a.m. at:

    Joe Serna Jr. CalEPA Headquarters Building
    Coastal Hearing Room
    1001 I Street, Second Floor
    Sacramento, CA 95814

For more information, please see the full Notice of Public Meeting.

Talking Points for Submitting Comments

While the State Water Board encourages comments to focus on new information presented in the final Substitute Environmental Document (SED), you are welcome to touch on any issue(s) related to the Bay Delta Plan. An important part of our job is to ensure the Water Board bases its decision on the best available science, and does not succumb to pressure from water agencies and their supporters who they’ve riled up through misinformation.

Begin your letter by introducing yourself. Why is this issue important to you? Perhaps you enjoy boating, fishing, swimming, backpacking or bird-watching in California’s watersheds. Share any personal stories or observations you might have. The Water Board is interested in all beneficial uses of the State’s water.

Remind the Water Board that California Fish & Game Code 5937 requires, “The owner of any dam shall allow sufficient water at all times to pass through a fishway, or in the absence of a fishway, allow sufficient water to pass over, around or through the dam, to keep in good condition any fish that may be planted or exist below the dam.”

Remind them that their 2010 flow criteria report determined that 60% of unimpaired flow between February and June would be protective of native fish in the San Joaquin River basin, so the proposed 40% of unimpaired flow is already a significant compromise.

Let them know which Alternative you support. Alternative 1 is the “no project alternative,” and Alternative 2 is 20-30% of unimpaired flow, so these are out of the question.

  • Alternative 3 (their recommended proposal) would require 30-50% of unimpaired flow, starting at 40%.
  • Alternative 4 would require 50-60% of unimpaired flow, starting at 60%.

For additional facts and figures, click here.

S.F. water agency opposes plan to save local salmon, cries ‘drought’

As published in the San Francisco Examiner on July 18, 2018.

Article by Robyn Purchia

About 150 miles beyond the Bay lies the Tuolumne River. Many San Franciscans visit the area to fish, raft, attend music festivals and see the bald eagles, beavers and river otters that call the area home. The river also visits us. Every time we turn on the tap, we welcome Tuolumne water collected in the Hetch Hetchy Reservoir into our home.

It should come as no surprise that taking water from the river impacts wildlife. Historically, the fall Chinook salmon run numbered 100,000. The number has declined to only a few hundred in recent years. While there are multiple reasons, the amount of water diverted is a major factor.

Thankfully, the state is closer to improving conditions for salmon and other wildlife. Following almost a decade of research, the State Water Resources Control Board released its final Bay Delta Plan earlier this month. Environmentalists and fishing associations label it a modest measure to increase the amount of water flowing in the Tuolumne.

But the San Francisco Public Utilities Commission in partnership with the Modesto and Turlock Irrigation Districts still oppose the plan. Officials say the plan could leave users vulnerable in times of drought.

Of course, we need clean water to survive. But taking water away from the environment unnecessarily doesn’t reflect San Francisco values, according to a recent survey. Before the SFPUC responds to the Bay Delta Plan, the agency should give San Franciscans an opportunity to learn more and offer their opinion.

The SFPUC isn’t in an easy position. Along with providing water to a growing population in the era of climate change, it is also obligated to support the Modesto and Turlock Irrigation Districts. These districts not only share Tuolumne water with San Francisco, they have senior rights to the resource. Unlike the SFPUC, the districts also represent farmers and more conservative Californians.

“It’s a good relationship with them, but not always perfect,” Steven Ritchie, the SFPUC’s assistant general manager for water, told me. “We have to be very close to them on technical issues.”

In partnership with the irrigation districts, the SFPUC funded research into the Tuolumne River ecosystem and health. Unsurprisingly, the studies recommend other measures to restore fish habitat, instead of limiting diversions. In the final Bay Delta Plan, the State Water Resources Control Board acknowledged the research, but didn’t find grounds to change its proposal.

Now the SFPUC and irrigation districts must decide how to respond. If the agencies litigate, the SFPUC may be violating the values of its customers, according to the Tuolumne River Trust.

In May, the environmental nonprofit worked with researchers at California State University, Fullerton to assess San Franciscan voters’ attitudes on water conservation. The survey found an overwhelming majority of San Franciscans conserved water during the most recent drought. Of those, 94 percent cited environmental concerns as a motivating factor.

Measures to protect and restore the Tuolumne River also received support from 92 percent of respondents.

“We think San Franciscans will be disappointed to learn the water we all conserved during the drought did not support the environment,” Peter Drekmeier, policy director at the Tuolumne River Trust, told me. “Instead, it was impounded behind dams and had to be dumped in one season last year during the near record storms.”

The SFPUC does not dispute that at the height of the most recent drought it had enough water in storage to last three years, and that it dumped the surplus. But collecting the resource was necessary according to agency officials. They are looking for ways to sustainably plan for a historic drought.

“Smart water supply planning and environmental protection are not mutually exclusive,” Ritchie said. “We can balance a healthy environment with a reliable water supply at the same time, and that’s exactly what we’re trying to do.”

If this is right, the SFPUC must make the case to San Franciscans. As a customer, I don’t want to fund litigation that would further push salmon down the path to extinction. When I turn off the tap, I want the water I save to flow to Californians – either human or non-human – that need it. What’s the point of conserving, if the water is going to get dumped?

Before the SFPUC responds to the Bay Delta Plan, it should hold a meeting to educate the public and take comment. To date, the agency has only discussed the matter in closed session. But the fate of such a vital resource deserves more sunshine.

“The Bay Delta Plan will have a major impact on the environment and the 2.7 million customers who depend on our drinking water every day,” SFPUC Commissioner Francesca Vietor told me. “The impact warrants a robust public discussion at the state and city levels to ensure all stakeholders understand the issue and the impact and have an opportunity to voice their concerns.”

Survey finds San Francisco’s water priorities are out of sync with the environmental values of its constituents

People conserve water assuming their actions will benefit the environment. However, in San Francisco and much of the Bay Area, this is not the case.

A recent public opinion poll of 402 San Francisco voters found that environmental protection is a strong motivating force for water conservation. The survey was commissioned by Tuolumne River Trust, and conducted by the Social Science Research Center.

93% of respondents said they personally conserved water during the recent drought. Of those, 94% said protecting the environment played a role in their actions. When asked if they would be more likely to conserve water if they knew it benefitted the environment, 72% responded yes. Conversely, only 21% said they would be more likely to conserve water if it only enabled more development.

“Unfortunately, the water we conserved during the recent 5-year drought did not benefit the environment,” said Peter Drekmeier, Policy Director for the Tuolumne River Trust. “Instead, the San Francisco Public Utilities Commission (SFPUC) hoarded it behind dams, only to dump it during last year’s near-record precipitation. The Tuolumne River experienced one excessive year of flows at the expense of five terrible years.”

While 75% of respondents could identify Hetch Hetchy as the source of their drinking water, only 12% could identify the Tuolumne River as the source that fills the Reservoir. The Hetch Hetchy Water System, which provides water to 2.7 million people in San Francisco, San Mateo, Santa Clara and Alameda Counties, is managed by the San Francisco Public Utilities Commission (SFPUC).

“The SFPUC has done a great job at branding Hetch Hetchy, but has failed to educate its customers about the Tuolumne River, which is the true source of their water,” said Drekmeier. “Saying our water comes from Hetch Hetchy is like saying our food comes from the grocery store.”

Staff at the SFPUC have been advocating against a proposed plan by the State Water Resources Control Board that would help restore the Tuolumne River and San Francisco Bay.

“The way the SFPUC manages its dams and reservoirs is clearly out of sync with the environmental values of its constituents,” said Drekmeier. “The SFPUC has opposed measures, such as revisions to the Bay Delta Water Quality Control Plan, aimed at restoring the San Francisco Bay-Delta and rivers that feed it.”

One reason the SFPUC has opposed the Bay Delta Plan, which would increase freshwater inflows into San Francisco Bay, is because it is planning to accommodate a rapid increase in commercial development in the coming years – a vision that is not embraced by a majority of San Francisco voters. 60% of survey respondents were unsupportive of creating more office space in San Francisco.

When asked about Plan Bay Area – a government-initiated roadmap that forecasts the addition of 1.3 million new jobs and 2 million more people to the Bay Area between 2010 and 2040 – only 11% of survey respondents believed the Plan would improve their quality of life, while 65% believed it would negatively impact their quality of life.

When asked if they would favor changing the way SFPUC Commissioners are appointed, more than twice as many people favored making the positions elected versus the status quo. The commissioners are currently appointed by the Mayor and approved by the Board of Supervisors.

Read the full results of the survey here: TRT Final Survey Report 06-29-18

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We Can Have a Vibrant Economy AND Healthier Ecosystems

The State Water Resources Control Board is in the process of updating the Bay Delta Water Quality Control Plan as required by the Clean Water Act. The State aims to achieve the co-equal goals of ecosystem restoration and ensuring a reliable water supply. Phase 1 of the Plan focuses on the San Joaquin River and its three main tributaries –the Tuolumne, Stanislaus and Merced Rivers –and southern Delta salinity standards.

The Bay Delta Plan calls for requiring a percentage of unimpaired flow –what would occur in the absence of dams and diversions –to flow down the three main tributaries and into the San Joaquin River between February and June. The current recommendation is 40% of unimpaired flow, with flexibility to adjust it between 30% and 50%, depending on whether biological and environmental goals are met.

The San Francisco Public Utilities Commission (SFPUC) manages the Hetch Hetchy Water System, which provides water to 2.7 million people in San Francisco, San Mateo, Santa Clara and Alameda Counties. The SFPUC has opposed the revised Bay Delta Plan, claiming it would severely impact the Bay Area economy. This is not the case.

Could the SFPUC run out of water?

The Tuolumne River Trust (TRT) has modeled what would happen if the six-year drought-of-record (1987-92) were to reoccur and the revised Bay Delta Plan were in effect. Even assuming water demand rebounded to pre-drought levels, the SFPUC could manage the drought with water left over in storage. This means that if the last 100 years of precipitation repeated, the SFPUC would not run out of water.

TRT 6-Year Drought Model

(223 mgd baseline, 40% unimpaired flow Feb-June)

TRT 6-Year Drought Model[1]

Note that the model assumes there would be no rationing in years 1 and 2 of the drought (since we wouldn’t know we were in a drought yet), rationing would be 10% in years 3 and 4, and 20% in years 5 and 6, for an average of only 10% rationing.

Why is the SFPUC concerned?

The SFPUC has not challenged TRT’s drought model, and in fact, its own modeling has accepted the outcome. However, the SFPUC is planning for what it calls a “Design Drought” –an 8.5-year drought that arbitrarily combines the drought-of-record (1987-92) with the driest two-year period on record (1976-77).

Regardless of how much water the SFPUC has in storage, it considers every year to be the beginning, or middle, of its Design Drought. The SFPUC states:

Our Level of Service objective for water supply is to survive the drought planning scenario (1987-92 followed by 1976-77) with no more than 20% rationing from a total system demand of 265 MGD [million gallons per day]…We need to plan for each year as if it is the beginning of our drought planning scenario.[2]

In anticipation of the Design Drought, the SFPUC claims that under the Bay Delta Plan’s 40% unimpaired flow, with demand at 223 MGD, rationing would have to begin at 39% for the first three years, and then increase to 49% for the next three years. This would leave 576,000 acre-feet in storage at the end of the six-year drought –enough to last more than two years. If history repeated, all of its reservoirs would refill after the drought. The excessive rationing would have been unnecessary.

When lobbying others, the SFPUC has misled influential people and groups by not explaining its extremely conservative 8.5-year Design Drought, nor that it’s figures are based on 2040 demand projections aimed at accommodating aggressive development as forecast by Plan Bay Area, leaving the impression that the Bay Delta Water Quality Control Plan would have a much more severe impact than under a realistic scenario.

What if we did experience a longer drought?

In a worst-case scenario, the SFPUC could purchase water from an agricultural irrigation district for about the same amount as it charges its customers. According to a recent study by the Sacramento Area Council of Governments:

Additionally, while all agriculture contributes significant value to the regional economy, specialty crops generated around $2,700 per acre annually –more than three times the value per acre than non-specialty crops.[3]

It takes about 3.5 acre-feet of water to produce an acre of crops, so according to the figure above, one acre-foot of water would generate $771 in income. Then there’s the “multiplier effect”–revenue generated through processing and distributing agricultural products.

Specialty Crop Cluster Direct Output Value

Specialty Crop Cluster Direct Output Value[4]

Using the above percentages for the multiplier effect, one acre-foot of water used to grow specialty crops generates $2,659. Lower value crops generate considerably less. The SFPUC currently charges its wholesale customers about $2,200 per acre-foot.

In other words, the SFPUC could purchase water from an agricultural irrigation district at a price that could allow farmers, processors and distributors to make as much money as if crops were being produced, but they wouldn’t have to do any work.

What are the SFPUC’s water rights on the Tuolumne?

The Modesto and Turlock Irrigation Districts, which share the Tuolumne with the SFPUC, have senior water rights on the River dating back to 1887. As the junior water rights holder, the SFPUC is required to let the first 2,400 cubic feet per second (cfs) (imagine 2,400 basketballs full of water) flow past its dams to satisfy the Irrigation Districts’water rights. Between mid-April and mid-June, the Irrigation Districts are entitled to the first 4,000 cfs.

Tuolumne River Water Entitlements

The SFPUC’s water rights are poor in dry years, but exceptional in normal and wet years. According to the Substitute Environmental Document (SED) for Phase 1 of the Bay Delta Water Quality Control Plan:

The 1922-2003 average calculated volume of water potentially available to CCSF [City and County of San Francisco] under the Raker Act was about 750 TAF/y [thousand acre-feet per year].[5]

The SED explains the SFPUC’s water demand as follows:

According to a SFPUC planning document, an average of 244 TAF/yis diverted from the Tuolumne River…based on data from 1989-2005.[6]

In other words, in an average year the SFPUC has the right to capture three times as much water from the Tuolumne as it uses. This allows storage to replenish quickly after a drought. At the height of the recent drought, the SFPUC had enough water in storage to last three years. 2016 was an average water year, and the SFPUC was able to rebuild its storage to 80%. Then came 2017 –the second wettest year on record in the Tuolumne River watershed –and the SFPUC had the right to capture enough water to last 12 years. Obviously, they didn’t have enough storage capacity to capture even a fraction of that water, so most of it had to be “dumped”into the River to prevent future flooding downstream.

SFPUC Tuolumne Storage

SFPUC Tuolumne Storage Graph[7]

You’ll note that the largest block of water in the above graph is labeled “Water Bank.”This is water the SFPUC can “pre-pay”to the Irrigation Districts when its reservoirs are full and it still has the right to capture more water. The SFPUC helped pay for the construction of Don Pedro Reservoir, which is owned and operated by the Irrigation Districts and is downstream of the SFPUC’s reservoirs, in exchange for the ability to “bank”water there. The SFPUC cannot directly access this water, but the set-up allows it to capture water at Hetch Hetchy that it otherwise wouldn’t be entitled to, and subtract an equal amount from its water bank. The water bank got low during the drought, but the SFPUC’s reservoirs remained close to full.

Knowing that its water supply depends on storing water during normal and wet years for future use during a string of dry years, the SFPUC has invested in storage. When full, the SFPUC’s reservoirs and water bank can store enough water to last six years.

SFPUC Storage Capacity

SFPUC Storage Capacity

To increase water supply even further, conservation groups have proposed that the SFPUC partner with the Irrigation Districts to capture excess water in very wet years and use it to recharge groundwater in the San Joaquin Valley for future agricultural use during dry years. Like the Don Pedro water bank, the SFPUC would not have access to this water, but could benefit from a groundwater water bank.

How does the SFPUC’s policy of hoarding water harm the environment?

During the recent drought, the SFPUC released only as much water from its reservoirs into the Tuolumne River as was required by a 1995 flow schedule. This schedule is based on baseflows –a minimum amount of water that must remain in the River, depending on water-year type (how wet) and the time of year. While people were inconvenienced by the drought, fish and wildlife experienced extreme conditions for five years.

In 2017, all of the water we conserved during the drought had to be “dumped,”providing one excessively good year for the environment at the expense of five terrible years. Had the Bay Delta Plan been in effect, the Tuolumne River would have benefitted, and the SFPUC still would have been able to replenish all of its reservoirs and much more.

 

Prepared by Tuolumne River Trust, June 21, 2018.

[1]Storage measured in thousands of acre-feet (TAF). One acre-foot equals 326,000 gallons.

[2]SFPUC Board meeting, January 10, 2017

[3]“Food System Multipliers for Specialty Foods,”Sacramento Area Council of Governments, July 25, 2016.

[4]Ibid.

[5]750,000 acre-feet equals 670 million gallons per day.

[6]244,000 acre-feet equals 218 million gallons per day.

[7]This graph, courtesy of the SFPUC, does not include Bay Area storage.

State Water Board plan would help restore the Tuolumne

As published in the SFChronicle on June 14, 2018

To improve the quality of our water and the health of our rivers and the San Francisco Bay-Delta, the State Water Resources Control Board is updating the Bay Delta Water Quality Control Plan as required by the U.S. Environmental Protection Agency. The board is considering requiring higher in-stream flows between February and June, which are critical months for baby salmon growth and migration. For the Tuolumne River, this would increase flows from an anemic 21 percent to a modest 40 percent of unimpaired flow.

During the recent drought, Bay Area residents and businesses stepped up to the challenge of conserving water and dramatically reduced their water use. In the Hetch Hetchy Water and Power System service area, water use declined by 30 percent between 2006 and 2016. But the Tuolumne River, which fills Hetch Hetchy Reservoir, rarely saw any of the water we saved, and it shows. The river is much lower and warmer than it should be, and salmon populations are barely surviving. Where well more than 100,000 salmon used to spawn, the salmon population has plummeted to the low thousands or even hundreds.

Some 2.7 million people in San Francisco, San Mateo, Santa Clara and Alameda counties get most of their water from the Hetch Hetchy Water and Power System, which is managed by the San Francisco Public Utilities Commission. The commission opposes the state board’s proposal to keep more water flowing in the Tuolumne River for three reasons:

Its policy and practice focus on human consumption, not environment or water quality. A 1995 agreement with the Modesto and Turlock irrigation districts — the senior water rights holders on the Tuolumne — that committed the commission to support the districts’ political position on in-stream flow requirements for fish and wildlife, regardless of what the best available science tells us. Irrigation districts are notorious for opposing environmental safeguards, yet the commission gave up its right to think and act in accordance with the environmental values of its constituents.

It wants to maximize stored water in case of drought. This policy of hoarding compromises the future of salmon and the entire ecosystem they support. While it has been demonstrated that the commission could manage a repeat of the drought years even with the revised Bay Delta Plan in effect, it is planning for an extreme scenario that arbitrarily combines the two worst droughts from the latter part of the last century. In a worst-case scenario, the agency could purchase water from an agricultural water district for less than it currently charges its customers.

The Bay Area is projected to grow in the coming years. Plan Bay Area, a road map for growth prepared by Bay Area Metro, forecasts the addition of 1.3 million jobs between 2010 and 2040, attracting 2 million more people to the region. Between 2010 and 2015, half of those jobs were already added, far outpacing the creation of new housing. As a result, the housing crisis and traffic gridlock have worsened, while our environment continues to suffer.

During the recent drought, the Public Utilities Commission released only as much water from its dams as was required by a 20-year-old flow schedule. The rest was impounded for future use. At the height of the drought, the agency had enough water in storage to last three years.

Then came 2017 — the second-wettest year on record — and the dam operators on the Tuolumne had to dump massive amounts of water to prevent future flooding. The river flowed at capacity from early January through May, and stream flows remained high throughout the summer. Had more water been released into the river during the drought, fish and wildlife would have benefited, and the agency still would have had enough water to refill all of its reservoirs twice over.

Without safeguards in place to require more water to flow down our rivers, there’s no assurance the water we conserve will benefit aquatic ecosystems. The Bay Delta Water Quality Control Plan is our best hope to restore a balance between human needs and those of the natural environment that makes our region so special.