The mission of the State Water Resources Control Board (SWRCB) is to balance water allocation and water quality protection for California.  With its latest river flows proposal, the SWRCB does neither.
The SWRCB held a hearing in Stockton on Friday, Dec. 16, to both present and seek public input on its revised Substitute Environmental Document (SED) for the Delta Water Quality Control Plan. If implemented, it would require that 40 percent or more of the natural flow remain in the Stanislaus, Merced and Tuolumne Rivers for ecosystem purposes, rather than be put to beneficial use for agricultural, industrial or municipal uses in our communities. It also would increase salt limits in the southern Delta, which would have detrimental impacts on long-term viability of Delta agriculture.
 This latest SWRCB proposal appears to be yet another ploy to promote the Governor’s Twin Tunnel plan. Even though the SWRCB cites the need for increased river flows to “improve aquatic ecosystems”, it appears the real desire is for additional water to flow through the damaged Delta to facilitate the export of billions of gallons of water south.
 The hearing brought out scores of people from across the Delta region who provided testimony opposing the SED. Members of the San Joaquin County Board of Supervisors, County officials, farmers, local water and irrigation districts and Delta stakeholders made a passionate plea as to why the plan fails on multiple levels and runs counter to the mission of the SWRCB:
 
The SED could result in
economic devastation
The State claims that as many as 250,000 acres could be fallowed each year and underestimates the region’s economic loss at approximately $64 million. In reality, the Central Valley would lose billions of dollars in revenue in addition to experiencing higher unemployment rates, reduced property values, harm to economically disadvantaged communities and workers, and permanent salt accumulation on prime agricultural land.
The loss of more water from our rivers and tributaries also means less groundwater recharge and more pumping, making it increasingly difficult to comply with the State’s Sustainable Groundwater Management Act.

The SED runs
counter to the law
 Water Code Section 11460 states that no water shall be diverted for export unless all the needs of the Delta watersheds are met including irrigation, municipal, industrial, and fish and wildlife. The SWRCB’s current proposal is in direct violation of State law.
The SWRCB concluded in 1978 that in order for all impacted fish populations to recover, virtually all exports would need to cease. Now that additional water is needed for the Twin Tunnels project, SWRCB seems to have changed its opinion and determined that exports are permissible and currently proposes increased flows.

The SED won’t ensure
increased fish populations
· The SWRCB’s representatives want to say that the County doesn’t care about the ecology and places farmers over fish. This is clearly wrong. San Joaquin County supports increasing water supplies statewide to ensure there is enough water for fish, farms and communities. We acknowledge that more water could be beneficial to fish populations, but we should look to the science and put the responsibility squarely on the true cause of fish population decline.  Reducing exports from the Delta should be targeted first, before turning to our communities which have been lawfully irrigating from the Stanislaus River and the Delta for over a century and responsibly addressing the fish needs.  
The State has historically ignored input related to the Delta, and the burden is on us to demonstrate the will of the people, the science, historical references and existing law, to prove that this latest attempt to drain us of our most precious resource must be shelved. We applaud the strong public engagement of our constituents. The regulators heard us loud and clear:  The current flows plan and corresponding Twin Tunnels project will spell disaster for the Delta region.
 In the meantime, San Joaquin County will continue to engage diverse stakeholders in actively promoting a comprehensive statewide solution that enhances the health of the Delta that does not pit one part of the State against another. Unlike the SED and Twin Tunnels proposals, we want to help develop a water plan that holds true to the SWRCB mission:  balancing water quality and allocation throughout California.