that lead to the 2010 Delta Flow Criteria did not involve any public interest or public trustbalancing that would be required under both its water quality and water right authorities. Forexample, the State Water Board did not consider what the impacts of these 2010 Delta FlowCriteria might be on upstream fish habitat, wildlife, water supplies, energy production or anyother beneficial use of water.Over the past several months, we have collectively performed analyses of some of the impactsto other beneficial uses and public trust resources if the 2010 Delta Flow Criteria or some lesser
version of the same “natural hydrograph” paradigm were implemented. T
he impact studies weperformed use the SWP/CVP system as surrogates for the types of impacts that would be seenby Sacramento Valley users and include separate analysis for the San Joaquin River system.While the State Water Board may decide to spread this possible new flow burden to other users,similar impacts would be felt by other users as well. While our studies are still ongoing, we havemuch valuable information to share with you.In short, these analyses conclude that:
The impacts of the 2010 Delta Flow Criteria would be devastating to other beneficialuses of water, including public trust resources, and would cause existing water qualityrequirements to be violated.
The criteria would not likely have the anticipated benefit to the Delta and may actuallymake habitat conditions in the Delta worse.
Reservoir levels in all of the major SWP and CVP reservoirs (Oroville, Trinity, Shasta and
Folsom would be greatly reduced and the new flow criteria would result in “dead pool”
levels (effectively empty) in all of them by the end of summer in half the years. Thiswould have devastating impacts to recreational uses and to temperatures for salmondownstream.
For example, lost cold water pools and reduced summer and fall flows wouldresult in a breach of temperature objectives below Shasta in about 90% of theyears, likely eliminating winter run salmon and naturally spawned fall run in theSacramento River.
Many times there would not be enough water to meet existing standards in the waterright decisions and those in the Biological Opinions of the federal fishery agencies.
While Delta outflow in the spring would be increased on average by 4.6 million acre-feet, this would come at an unfathomable water supply cost:
About 700,000 acres of agricultural land in the Sacramento Valley would beforced out of production. (As a point of reference, the entire rice crop in theSacramento Valley is typically about 500,000 acres).
No reservoir storage releases were made to support Delta exports in thesestudies. Exports would be cut by an average of 2.8 million acre-feet, about inhalf.
Over 1 million acres of agricultural land south of the Delta would be forced outof production.
Municipal and Industrial users west and south of the Delta would lose onaverage 1.1 million acre-feet (which is about the urban water demand for theentire San Francisco Bay Area Region).
Water supplies to wildlife refuges both north and south of the Delta would begreatly reduced and the Pacific Flyway benefits of rice production in the fallwould be reduced.