ToDo!!! Send comments to the State Water Board by March 29th

Is everyone just trying to confuse us??? Originally it sounded like the State Water Resources Control Board (SWRCB or commonly called the State Water Board) Substitute Environmental Document (SED) may be a good thing. At least reading their webpage.

Now we believe it’s a very bad thing from the reports of attendees at the March 20th public hearing. It sounds like the SWRCB is planning to reduce freshwater flows on the San Joaquin River (higher flows have been responsible for starting to improve the return of the salmon and help bring fresher water into the South Delta). In addition, they are raising the amount of salt allowed in the water – salt that gets into the tributaries from the South San Joaquin farms and then ruins Delta farmlands.
Spilled Salt

We need to say “NO!

Please email your comments by March 29th


  • We need MORE fresh water released into the San Joaquin, not less. The State Water Board’s own Delta Flows report released in August 2010 called for more fresh water for the Delta!
  • We need LESS salt in the San Joaquin River for use by Delta farmers, not more! The Delta farmers have senior water rights. They deserve the freshest water first, not the South San Joaquin valley farmers who have junior water rights, many of whom are mega-corporations and should not be getting subsidized water, let alone the freshest water. It is those desert farmlands that leech out salts and selenium into the runoff water. Save the Delta farms!

Please send in comments (due March 29th).


Please include the subject line, “Comment Letter – Bay-Delta Plan SED.”

  • Via email: You may also submit your comments to Ms. Townsend by fax at (916) 341-5620, by email at
  • Via snailmail addressed to:
      Jeanine Townsend
      Clerk to the Board
      State Water Resources Control Board
      P.O. Box 100
      Sacramento, CA 95814-0100

Details and Background

The State Water Board is in the final week of comments on its Substitute Environmental Document (SED).

The board’s webpage describes the SEP as proposed changes to the Bay-Delta Plan as:

  1. a new narrative February through June Lower San Joaquin River (LSJR) flow objective applicable to the salmon bearing tributaries to the LSJR (the LSJR, Merced, Tuolumne, and Stanislaus rivers) and an associated program of implementation to support and maintain the natural production of viable native LSJR watershed fish populations migrating through the Delta; and
  2. revised numeric southern Delta salinity objectives and an associated program of implementation to protect agricultural beneficial uses in the southern Delta.

Sounds like positive changes for the Delta – Yes?

HOWEVER, at the March 20 review meeting, it was reported by attendees there that “Westside San Joaquin Valley farmers throwing South Delta farmers under the bus” and saying that at the State Water Resources Control hearing on San Joaquin River Flows as part of the San Francisco Bay/Sacramento-San Joaquin Delta Estuary (Bay-Delta) Program, Phase I, John Rubin, Senior Council for the San Luis Delta-Mendota Water Authority, made a presentation to the State Water Resources Control Board that was an all out attack on the future of farming for South Delta farmers. That the SED calls for 35% unimpaired flows on the San Joaquin River and a weakening of salinity and water quality standards in the South Delta from 0.7 e.c. to 1.0 e.c. (measurements of electrical conductivity used to measure salinity).

This would be a weakening of the standards, not improvements for fish and farmers as, it seems, misleadingly stated on the website.

Furthermore, it was reported that the weakening of standards was

    “not sufficient for San Luis Senior Council Jon Rubin. The bulk of his presentation was predicated on how salinity in the South Delta could be raised to 1.2 or 1.4 e.c., with Delta farmers, according to his science sources, suffering small crop losses. It certainly takes some gumption for Rubin, who represents several districts responsible for loading the San Joaquin River with salt, selenium, and boron and that are pushing for the construction of the peripheral tunnels so they can have the best in water quality and reliability, to expect South Delta farmers to be limited in crop choices and to experience losses in production levels.

    We believe that this is an alarm bell for all Delta and Northern California farmers. If Westside growers are willing to sacrifice senior water rights holders and fellow farmers in the South Delta today, they will come for every other farmers’ water rights and ability to remain productive tomorrow.”

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