Comments on Bay-Delta Flow Requirements Mar 17, 2017 Comment Letters Agency: State Water Resources Control Board Subject: ACWA Comments – 2016 Bay-Delta Plan Amendment & SED Letter excerpt: ACWA is concerned that the approach taken in the draft Bay-Delta Plan amendment does not provide reasonable protection of all beneficial uses of water and fails to appropriately balance the multiple competing uses of water as required by state law. The approach is inconsistent with the coequal goals of improving water supply reliability and enhancing the Delta ecosystem established in the Delta Reform Act of 2009. The approach is also inconsistent with the Sustainable Groundwater Management Act (“SGMA”) and would undermine implementation of the California Water Action Plan, particularly in the areas of improving water supply reliability, sustainably managing groundwater, and providing safe drinking water for all communities. On March 10, 2017, ACWA’s Board of Directors unanimously adopted the attached policy statement on Bay-Delta flow requirements, which is incorporated into the following comments by reference. In the policy statement, ACWA expresses deep concerns regarding the draft Bay-Delta Plan amendment’s proposal to base flows on a percentage of unimpaired flow, and presents an alternate approach that supports the Governor’s request that flow requirements be developed through a negotiated, collaborative process. Download ACWA’s comment letter
