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Business as usual? CSPA and C-WIN prepare to testify before the State Water Resources Control Board on the State Board's Bay-Delta Strategic Plan

July 9, 2008. Citing the, "present reality of a disintegrating Delta ecosystem, seriously polluted waterways and collapsing fisheries, coupled with over half a billion acre-feet of water rights in a state that has an average runoff of 77 million acre-feet [as] a searing indictment of the failures of the State and Central Valley Boards to enforce the law," CSPA'S Executive Director, Bill Jennings, and Carolee Krieger, President of the California Water Impact Network, plan to testify at the hearings to take place on the State Board's Bay-Delta Strategic Plan at the State Water Control Board headquarters in Sacramento next Wednesday, July 16th.

In advance of their testimony, CSPA and C-WIN delivered a series of, "Comments on the Draft Strategic Workplan for the Bay/Sacramento-San Joaquin Delta Estuary," on July 8th. The extensive document indicts the, "State Board [as failing] to properly carry out its constitutional and statutorily duties to both protect the public trust, and to prevent waste and unreasonable use of water in California."

Stating that the, "Strategic plan appears to C-WIN and CSPA to be an attempt to buy time. What the Strategic Plan does not do is solve any of California's well-documented water problems," the comments found a number of specific issues that need to be addressed.

These issues include: How much water does the Delta need? How Will the Board Create And Manage A Comprehensive Delta Monitoring Plan? When Will Necessary State-Of-The-Art Fish Screens Be Required On Delta Export Pumps? What New Conditions On Export Pumping Will Be Implemented In Light Of Increased Water Exports And Resulting Reverse Flows To Protect The Bay/Delta Ecosystem? What Is To Be Done About Current Salt Loading To The San Joaquin River And Delta? When Will Water Storage Levels Be Increased To Protect River Flows In The Likely Event Of Dry Water Years In The Future?

Instead of finding a sincere effort to develop a working Bay-Delta Strategic Plan, CSPA and C-WIN find that the, "The Workplan Elements are largely a fictionalized history coupled with a recital of current programs." The current programs are largely a list of failures which have resulted in the delta's severely impacted state. These include programs on water quality and contamination, failure in monitoring and enforcement of the NPDES Discharge Requirements Program. failure to reduce discharges from the Irrigated Lands Program, failure to monitor and clean up discharges exceeding total maximum daily loads of pollutants, failure to deal with the issues of once-through-cooling of delta power plants, failure to set sediment quality objectives, failure to manage the 212 confirmed exotics and 123 suspected exotics that had already invaded the estuary, failure to deal with agricultural runoff from farmed delta islands, failure to adequately fund the program to identify the effects of pervasive ammonia concentrations, failure to adequately fund the program for the Selenium Screening Study for the Delta, failure to institute a Comprehensive Monitoring Program for the delta, failure to enforce San Joaquin River Flow and Southern Delta Salinity standards, failure to adequately review Water Rights and Other Requirements to Protect Fish and Wildlife Beneficial Uses and the Public Trust, failure to ensure that the SWP's and CBP's methods of diversion are reasonable, beneficial and protect the Public Trust, and failure to conduct water right investigation, enforcement and other activities to ensure flows sufficient for wildlife.

In summing up, the document states that, "CSPA and C-WIN believe that the current Draft Strategic Plan is part of a long-standing and continuing attempt by the State Board to increase exports from the Bay/Delta watershed while appearing to investigate and modify the water rights of in-watershed users."

In short, business as usual.

The complete and extensive document can be read at: Comments on the Draft Strategic Workplan for the San Francisco Bay/Sacramento-San Joaquin Delta Estuary