Comments Submitted on Bay Delta Water Quality Control Plan

1.18.24: AquAlliance spent significant time submitting comments on the draft Staff Report/Supplemental Environmental Document (“SED”) for the Water Quality Control Plan for the San Francisco Bay/Sacramento-San Joaquin Delta Estuary (“Plan”).

The State Water Resources Control Board’s plan seeks to curtail some water diversions from streams and rivers to help struggling fish and water quality (the plan has been delayed for 20 years). The SWRCB is at fault for the water quality and fish mess because over the decades they approved water diversions five times over what could ever be available.1 They finally produced this EIR equivalent that at least opines that surface water curtailment could affect groundwater use, but they have no mitigation prepared to stop groundwater damage as required by CEQA. This is where AquAlliance comes in, pointing out the plan’s failures to encourage corrections.


1 The unimpaired runoff of the Sacramento River basin is 21.6 MAF, but the consumptive use claims are an extraordinary 120.6 MAF – 5.6 times more claims than there is available water.