Although not as far along, the State Water Board also plans to establish unimpaired flows of 45 to 65 percent for the Sacrame nto River. They also would apply to its tributaries through the interior Delta, including reverse flows in the Old River (pictured north of Tracy) and the Middle River. Photo by Vicky Boyd

By Vicky Boyd

The State Water Board’s proposal to send nearly 300,000 acre-feet of additional water down the San Joaquin River and its tributaries between February and June could significantly harm regional agriculture and upend the state’s water rights system, say county agricultural leaders.

The plan, released July 6, is the state’s third attempt in nine years to revise the Bay-Delta Water Quality Plan and prevent what it calls an “ecological crisis” in the Delta.

But the State Water Resources Control Board has disregarded extensive comments from farm and water groups about the ill-conceived plan, and many of the previous sticking points continue to plague this proposal, said San Joaquin Farm Bureau Executive Director Bruce Blodgett.

“Again, we have major concerns about the whole process, and they continue to ignore them,” he said. “With 40 percent (unimpaired flows), you’re starting to talk about billions of dollars of economic impact and it will maybe help a hundred fish. It’s not a balanced solution.”

Steve Knell, Oakdale Irrigation District general manager, agreed, saying the water board continues to ignore science.

“There’s no peer-reviewed document that says more water equates to more fish on its own because you have so many problems left in the rivers, like (lack of) habitat and places to rest,” he said. “And there’s a predator pool in the Delta. If you’re not going to change that, you’re just sending more fish down to feed them.”

Farm Bureaus and farmers in the affected counties are currently organizing a rally in Sacramento, Aug. 20, a day before the water board’s meeting when it is expected to start the hearing process to adopt the proposal.

“So hopefully, something can be said or done in the meantime, but ultimately I see this going to court,” said SJFB First Vice President David Strecker, a Delta area farmer.

Although the State Water Board is not as far along in its plans for the Sacramento River and tributaries, a state framework report calls for unimpaired flows of 45 to 65 percent as well as cold-water temperature targets.

The deadline to submit written comments on the San Joaquin River proposal was July 27. Blodgett said that wasn’t enough time to review the complex document and formulate written comments, and Farm Bureau would ask for an extension.

Flow objectives
The plan, known officially as the “proposed final substitute environmental document,” contains flow objectives for the Lower San Joaquin River and its three main tributaries: the Stanislaus, Tuolumne and Merced rivers. The state defines unimpaired flows as surface water that would accumulate from precipitation and flow downstream if there were no reservoirs or diversions to change the quantity or timing.

A 2010 state technical report determined 60 percent unimpaired flows in the San Joaquin River from February through June and 75 percent unimpaired flows in the Sacramento River would preserve the natural system to which native fish have adapted.

The recent proposal doesn’t go quite that far but does require each San Joaquin River tributary maintain an average of 40 percent unimpaired flow – or 288,000 acre-feet between Feb. 1 and June 30. Within those months, the flows could range from 30 to 50 percent – 174,000 to 485,000 acre-feet – under an “adaptive” management program to meet fishes’ lifecycle needs.

For Delta farmers like Strecker, the increased flows could be disastrous.

“They call them unimpaired flows,” he said. “I’m calling them uncontrolled flows, and when you don’t have control of the water, that potentially means flooding in the Delta.”

Strecker cited as an example the flooding he experienced in 2016, when Delta flows were near flood stage. The water didn’t lap over the levees. Instead, it seeped up through the soil, damaging established crops, such as alfalfa, and preventing planting of others.

Mary Hildebrand, an SJFB Water Advisory Committee member, farms in the south Delta and said the land is slightly higher in elevation, so flooding like Strecker experienced wouldn’t be as much of a concern. What she is worried about is how the higher flow requirements might force growers upstream to idle ground.

“It could make our low summer flows even lower,” Hildebran saidd. “If they do fallow ag ground in the tributary basins, all of the flow that comes by me in late summer is tailwater. I don’t think the increased flows are going to help us in our area, and it might make our summer flows even worse.”

Impacts on ag
Economic impacts to agriculture would increase as the unimpaired flow percentage increases. At 40 percent unimpaired flows, the water board estimates the region’s annual ag output would drop by $69 million – or 2.5 percent from a baseline annual average ag output of $2.6 billion. The reductions could range from $35 million with 30 percent flows to $123 million with 50 percent flows, according to the water board report.

But that differs significantly from the $250 million in combined annual losses that the Oakdale and South San Joaquin irrigation districts have estimated the measure will cost them.

“The only word we can come up with is this whole plan is just devastating to ag,” Knell said.

The Merced Irrigation District estimates the flow requirements could cost the Merced River watershed between $750 million and $1.3 billion annually in below-average, dry and critical water years, according to figures from the Merced Irrigation District. And the Modesto and Turlock irrigation districts estimate 50 percent unimpaired flows could reduce their combined service area’s total economic output by $920 million annually, according to California Farm Bureau figures.

The water board’s proposal also would require a minimum 700,000 acre-foot “cool pool” be left in New Melones Reservoir at the end of the water-use season in September. OID and SSJID together hold senior water rights to the first 600,000 acre-feet in the reservoir, which has a capacity of 2.4 million acre-feet.

During the critically dry years of 2014-2016, New Melones performed as designed, Knell said. It allowed the two districts to continue water deliveries to farmers and cities with only minor reductions. But the water board’s plan does not include any dry year contingencies.

“Under this plan, we would have been out of water in 2014,” Knell said. “We wouldn’t have had water in 2015 or 2016 at all.” Hydroelectric power generation also would take a significant hit, he said. About 70 percent of the districts’ income is derived from electricity sales. Without that income, they would have to raise water rates significantly.

Although OID and SSJID, along with several other water districts, have proposed alternative plans that balance the needs of fisheries with ag and urban water users, the suggestions were basically ignored in the final draft, Knell said.

The Water Board acknowledges that as surface diversions decrease, water users will turn to groundwater to make up the shortfall. But Blodgett said the report discounts the Sustainable Groundwater Management Act of 2014, which seeks to eventually balance groundwater withdrawals with recharge.

“They’re making the assumption that people will just pump more groundwater. But with SGMA in place, that just can’t happen,” he said.

Calling it a “one-sided type approach,” SJFB Second Vice President Ken Vogel questioned the water board’s stated goals. “They’re talking that they want to prevent an ecological crisis (in the Delta),” he said. “They want a healthy environment. They want healthy agriculture. They want healthy communities, but we in ag are also going to have to work within the SGMA requirements. They’re attacking both of them – how is that going to keep a healthy ag and a healthy community?”

Salinity goals for the southern Delta
One part of the proposal, which has received little press, are the salinity goals, Hildebrand said. Currently, the Delta salinity goals are 0.7 EC (a measure of salinity) April through August and 1.0 EC September through March measured at four fixed points in the Delta. The update proposes a year-round objective of 1.0 EC measured at three channel segment locations averaged together and one fixed point.

Without addressing salinity levels in the stagnate pools within the Delta, Hildebrand said the board will find it nearly impossible to meet the new goals.

“Even with the increased flows, they are not addressing the reverse flows or the stagnate areas of the Delta,” she said. Although the Water Board’s document said the current standards are more stringent than are needed to protect crops, Hildebrand disagreed, citing University of California studies. Even today, some producers in the south Delta experience salinity damage to their crops.

“It’s mainly in those areas where they’re pumping out of the stagnate zones,” she said. “Using leaching factors, we don’t agree with them, particularly in alfalfa where you have compaction over the life of the crop.”