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Board should reject flows plan, coalition says

Issue Date: August 1, 2018
By Dave Kranz

Urging the state water board to reject a proposal to redirect flows in three Central California rivers, a coalition of more than 50 agricultural, water and business organizations encouraged the board to renew efforts for voluntary agreements with affected water users.

"This unified response from groups representing farmers, ranchers, and urban and rural residents alike demonstrates the impact the water board's proposal would have, and the need for the board to explore alternative methods that would help fish without the severe human cost of its current approach," California Farm Bureau Federation President Jamie Johansson said.

The State Water Resources Control Board is scheduled to vote on the proposal next month. It would commit much more water in the Stanislaus, Tuolumne and Merced rivers to "unimpaired flows" intended to benefit salmon and other fish.

The agricultural-water-business coalition said the proposal would have "large and unprecedented" impacts on the affected region and that "alternative pathways exist for the achievement of fish and wildlife goals."

The joint letter said the board should direct its staff to engage people and agencies in the northern San Joaquin Valley "in a renewed, vigorous and realistic effort at voluntary settlement agreements that are intended to reconcile fish and wildlife objectives with the long-established and marvelously productive landscape of human water use and settlement on those rivers."

Using figures from the water board proposal, the coalition said redirecting 30 percent to 50 percent of the water in the three rivers—as the board staff has proposed—would reduce surface water diversions in the three affected watersheds by an average of 180,000 to 490,000 acre-feet a year, and by up to 900,000 acre-feet in dry years.

"Cold water pool requirements would commandeer an additional 800,000 acre-feet of reservoir space through the summer," the letter said, adding that the plan would also reduce groundwater supplies by an average of 118,000 to 370,000 acre-feet a year through reduced recharge and increased pumping—just as local districts are working to comply with the Sustainable Groundwater Management Act.

Irrigation districts with facilities on the Stanislaus, Tuolumne and Merced rivers have estimated the socioeconomic impacts from reduced irrigation water supplies would run in the hundreds of millions of dollars annually.

Well beyond the impacts to farms and water districts, the coalition said, shockwaves from the board's proposal "are sure to ripple outward to adversely affect businesses, local governments and disadvantaged communities throughout the northern San Joaquin Valley."

Combined with the impact of SGMA, the letter said, the unimpaired-flows plan could lead to "additional, significant losses relating to long-term investments in trees, vines and farm equipment; loan carryovers, debt repayment and default issues; the devaluation of land and other real property; and the stranding of significant infrastructure capacity."

The coalition also warned that the proposal violates the state Constitution's requirement that water be used reasonably, "by proposing the extraction of huge volumes of 'unimpaired flows' from otherwise legal and beneficial water users, at enormous human cost and without any reasonable and commensurate assurance of benefit to the environment."

Under the state Constitution, the letter said, "water used or taken from other water users in service of environmental ambitions must, like any other use of water, be reasonable in the face of the scarcity of the water resource, and the competing uses for that water."

Describing the flow proposal as "an expedition in scientific uncertainty," the coalition encouraged the board to support "voluntary and creative solution-finding" such as the use of functional flows—releasing just the right amount of water into rivers at the appropriate time to benefit fish—and non-flow alternatives including measures to create additional habitat or address species that prey on protected fish.

"While stakeholders and regulators may disagree about the particulars of such plans, they should be seen—and embraced—as evidence that there are ways for water users and regulators to move into the future together on fishery issues, rather than opposite each other in courtrooms," the letter said.

The coalition warned that the board's proposal threatens "a systemic collision between human water rights and environmental flows."

"Until every opportunity has been exhausted for creative conservation and collaboration," the letter concluded, "a difficult and damaging regulatory path which is premised upon uncertain future fisheries successes should be avoided at all costs."

The letter was signed by 54 organizations, including the Association of California Water Agencies; California Bankers Association; California Chamber of Commerce; Southern California Water Coalition; the Modesto and Turlock irrigation districts; agricultural and water organizations representing a wide range of crops, commodities and regions; and 26 county Farm Bureaus. The full text of the letter and full list of signatories may be found online at, under the "Unimpaired Flow Standards" tab.

With the formal comment period on the flows proposal now ended, opponents of the plan are organizing other ways of protesting it.

The Assembly member representing much of the region affected by the proposal, Adam Gray, D-Merced, has announced plans for a noontime rally on the north steps of the state Capitol in Sacramento. The rally has been scheduled for Aug. 20—the day before the water board begins two days of meetings to consider adopting the proposal.

The water board meetings will be held Aug. 21-22, beginning at 9:30 a.m. each day, in the CalEPA Headquarters Building, 1001 I St., Sacramento.

The board is also moving forward on a separate plan to redirect flows in the Sacramento River watershed.

(Dave Kranz is editor of Ag Alert. He may be contacted at

Permission for use is granted, however, credit must be made to the California Farm Bureau Federation when reprinting this item.

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