On January 19, GSSA, San Francisco Baykeeper, the Bay Institute, Defenders of Wildlife, Institute for Fisheries Resources, and the Pacific Coast Federation of Fishermen’s Associations submitted our official technical comments to the State Water Resources Control Board regarding the September 2023 Staff Report in support of potential Sacramento/Delta Updates to the Water Quality Control Plan for the San Francisco Bay/Sacramento-San Joaquin Delta Estuary (Bay-Delta Plan).
The nearly 160-page document makes the case that neither the proposed project nor the Voluntary Agreement (VA) alternative:
- comply with federal and state mandates to restore and maintain the chemical, physical and biological integrity of the nation’s waters, reasonably protect fish and wildlife beneficial uses of those waters, and protect the public trust;
- adequately define viability as called for in their respective proposed narrative objectives;
- establish objectives and/or targets relating to fisheries, estuarine habitat, and other beneficial uses;
- include a detailed program of implementation (POI) capable of attaining Plan objectives;
- adequately analyze the potential effects of alternatives on fish, wildlife, habitats, and associated beneficial uses, including impacts to the salmon fishing industry
- adequately analyze the effects of climate change; and
- adequately analyze how alternative water supplies can offset impacts of flow improvements.
Under the VA alternative, the current status quo of species decline towards extinction, fisheries closures, increasing impacts of harmful algae blooms, and ecosystem collapse would not improve and would likely worsen.