Metropolitan Special Committee on the Bay-Delta discusses Cal Water Fix

The project’s ecosystem measures, seismic risk analysis, climate change adaptation, and draft EIR discussed; also, a brief review of the State Water Board’s water quality control plan updateMetropolitan Water District Seal

At the September 29 meeting of Metropolitan’s Special Committee on the Bay-Delta, committee members heard a presentation on the California Water Fix project, including information on the seismic reliability and climate change adaptability, as well as brief review of the State Water Board’s ongoing process to update the Bay Delta Water Quality Control Plan.

California Water Fix Update

Steve Arakawa began by saying he would be covering different aspects of the California Water Fix that relate to Metropolitan Board policies but haven’t been previously covered, such as fishery and ecosystem improvements, seismic reliability, and being adaptable to climate change. He would then cover some of the basic updated cost information, as well as some of what they are proposing to include in their EIR comments.

At a future meeting, he will return with further details on the costs, how it fits into Metropolitan’s Integrated Resources Plan, and reviewing the agreements and commitments necessary to implement the project. “This would provide for deliberation that we would anticipate in first half of 2016 in helping to support any decision making that would be needed as the project moves forward,” he said.

Ecosystem Measures

The Board’s policy does look to improve ecosystem aspects of the Delta because those are certainly tied in with water supply reliability, Mr. Arakawa said. “I think the main thing is correcting flow patterns,” he said. “Since the SWP was initially designed and implemented, there was always a thought that it needed to be improved or updated to deal with the fact that the diversion in the south Delta creates reverse flows in the Delta. Every step of the SWP history, every replannin3a_Presentation__Page_05g process, every deliberation, and every regulatory process has focused on the effects of those reverse flows on fish, so one of the key features of the proposed water fix that includes the tunnel pipelines, is that it has a new diversion point off the Sacramento River in the north end of the Delta that allows some of the export water to move through the tunnel, and the remaining amount of water to stay in the Delta channels. It’s a dual water conveyance facility. Part of the water goes through the tunnel, part of the water goes through the Delta channels, but in doing so, it has a huge benefit of helping to correct those reverse flows.”

Another benefit of the proposed project is that a diversion point along the Sacramento River as presently proposed is a better site for fish screening, he said. “The current intake is at the south end of the Delta, and all the water that is going towards the export pumps ends up at Clifton Court Forebay, and that southwestern corner of the Delta ends up being like a dead end,” Mr. Arakawa said. “This north intake would allow for a different diversion point with a much better place for screening fish and a much more effective way of screening fish. Because of its location on the Sacramento River where adequate bypass flows could be provided, fish could be enticed to move downstream away from the intake, and likely significantly less salvage, if any at all, at that intake versus at the south Delta pumps.”

Another feature of the proposed project is more real time monitoring to understand how to operate the system more effectively and efficiently both for fish and for water supply. “That’s going to be key,” he said. “I think as new technological improvements occur, and this kind of an approach is implemented, there is going to be a more effective way of protecting both water supply and fish in the Delta.”

Other measures include a fish gate at the head of Old River to keep fish going down the San Joaquin River during key migration periods for fish, and some operational measures that the fish agencies do believe would provide additional protection, including some additional restraints in the south Delta and some additional outflows. “The key to that is the further scientific review and decision making process to really understand whether those measures do in fact provide additional protection for fish,” he said.

An addition to the infrastructure and operational improvements included in California Water Fix, there is a parallel process called California Eco Restore to implement restoration of habitat, he said. “This is separate from the California Water Fix in terms of the permitting approach,” he said. 3a_Presentation__Page_06It would be a separate process of implementation. It would include two aspects, one is implementing the habitat that’s required under the existing permits of the state and federal projects, but also adding to that habitat that would provide broader benefits.”

California Eco Restore’s goal of 30,000 acres is intended to kickstart things to demonstrate it can be done, as well as to provide the basis for future habitat restoration, he said. “It’s really to take the bull by the horns and implement these projects that have been in front of us for a number of years, determining how those projects work, and then moving forward with additional projects after that.”

He then presented an aerial map of the Delta, pointing how the flows from the Sacramento River come in from the north and the flows from the San Joaquin River coming in from the south meet at the confluence and flow out towards the San Francisco Bay. 3a_Presentation__Page_07He noted the location of the State Water Project pumps and Clifton Court Forebay in the south Delta, and the Central Valley Project pumps, which are in a similar proximity but pump directly from the Delta channels. “I mentioned reverse flows has been a key aspect of concern for going all the way back to the original design of the State Water Project,” he said. “Normally these flows would be going out towards west or north and then west, but with the pumps on, the flows over a tidal cycle tend to reverse, going towards the south. So the whole idea is trying to provide as much downstream flow as possible in those two downstream channels, particularly in fish sensitive times, and I’ll say the fish sensitive times … essentially January through June.”

With the proposed project and the proposed operations, the reverse flows would reduce significantly,” Mr. Arakawa said. “Without the project, the reverse flows have been on average being about 2200 cfs flowing south toward the forebay and the CVP exports pumps. With the proposed project, that reverse flow would go from -2200 towards the pumps to about -230, a significant reduction during a fish sensitive time. During parts of those months, certainly there would be more probability of positive flows in those channels, so a pretty significant improvement … certainly reducing those flows significantly.”

Seismic Risk Analysis

It is a board policy to provide for the reliability of the system in the Delta and to have an ability to count on those supplies and to be able to respond to a catastrophe like a major earthquake in the Delta, Mr. Arakawa said. Information has been presented at past meetings regarding how the proposed project would operate under such circumstances, and in the current proposal, the main features of the physical system are about the same, he said.

There has been a lot of analysis on seismic risk in the Delta, looking at the number of earthquake faults running through that area or adjacent to that area, what the potential earthquake events might be, and 3a_Presentation__Page_10what the resulting ground motions of the area might be under a major earthquake. “Numerous experts in the field have been involved for a number of years going back to the mid 200os looking at the levees, the earthquake faults, and what they think the ground motions and displacements would be,” he said.  “Many of these experts are world renowned; they serve on key commissions looking at infrastructure safety, so a lot of technical effort and a lot of renowned expertise has been applied to this Delta region. There have been several years of studies, all the way up to the most recent, looking at not only design features but earthquake response and mobilization strategies.”

Seismic modeling studies done by the state show a potential 6.5 magnitude earthquake possible on the Southern Midland Fault, which runs through the western end of the Delta from north to south, he said. “With a maximum probable earthquake of about 6.5 or more, the analysis shows 50 breeches and 20 island failures, so 20 islands would fill up with water,” he said. “A lot of modeling work was done to look at what does that mean to the Delta water quality if you were to have such an event, how quickly does that Delta area fill up with saltwater and what is the concentration of that salt water.”

3a_Presentation__Page_11He noted that on the slide, the red area indicates high salinity water with 5000 units of electrical conductivity and the blue is the fresher water at about 400 units. He then related that to the more-familiar water quality parameter of total dissolved solids (TDS), with the blue indicating about 228 TDS and the 5000 red area about 2850 TDS. For reference, he noted that the State Water Project water supply averages about 250-300 TDS. “Obviously the red area with those higher TDS is a result of the salt water coming from Suisun Marsh and Suisun Bay up into the Delta area,” he said.

With this type of earthquake, we see that there’s a huge risk of impact to our water supply from the maximum probable earthquake that the seismic experts believe probably will happen in the next 30 to 40 years or so,” he said. “Metropolitan and other water interests have been looking for many years to have a response plan. We talk about moving water through a Middle River pathway area, making sure those levees are built up sufficiently so that they would not slump below the water level as a result of a major earthquake in the area.”

Over the last several years, they have been working on being prepared to provide a path for fresher water from the north Delta to come down to the export pumps and provide a significant supply within six months of a major earthquake, he said. “We’ve done the preparation of rebuilding some of the key levees and having placement of materials to create that pathway following an event, and to date, a significant amount of material has been placed in the surrounding area,” he said. “More needs to be done, and facilities are currently being implemented to allow for further materials to be moved into the area as an activity or as an event occurs and actions need to be taken.

The analysis shows that if there was an event like that, instead of three years to resume operations, it would take less than 6 months to provide a significant amount of water, Mr. Arakawa said. “With the Middle River pathway, we’re thinking at a minimum, maybe half of the water. As further improvements are made, even more than that, so that’s a significant thing in terms of being prepared for an earthquake like this.”

3a_Presentation__Page_13Mr. Arakawa then turned to the seismic reliability of infrastructure itself, noting that Metropolitan’s structural engineers have researched the issue, looking at earthquakes throughout different parts of the world, major earthquakes that have occurred in different regions, and what types of systems have they used in order to create a dependable system. In June of 2014, one of their engineering experts, Howard Lum, discussed the results of their research into the seismic fitness of the proposed facility.

Since that time, there have been some alignment refinements to the proposed pipeline tunnel project, but the major design features are pretty much the same, other than relocating the pumping plant towards the south end of the Delta,” he said. “But in terms of the tunnel system and how that tunnel system would be constructed and designed and the materials that would be used, it’s essentially the same system. So what he provided in that meeting a little over a year ago as far as his findings still stand today in terms of this tunnel being the best approach for being able to withstand a major earthquake in this region.”

One of Mr. Lum’s key findings was that because the tunnel is 150 feet underground, those kinds of systems are much more capable of withstanding a major earthquake then something at the surface, Mr. Arakawa said. 3a_Presentation__Page_14The other key finding was that tunnels built using concrete lined segments provides a way of creating a system that’s able to withstand a lot of movement that occurs with a major earthquake; segmental liners have a better performance because they are able to have joints and able to be flexible, he said. “So overall, the system that we’re talking about in the proposed project is essentially the same system that he had evaluated about a year and a quarter ago and that has many of the attributes that other significant tunnels in other parts of the world are using in order to withstand a major earthquake.”

Liquefaction is a concern as well, he said. “With being in a system where you are draining major watersheds, being able to create a system that’s not subject to liquefaction is key, and because of the tunnel depth, it would be able to avoid that liquefaction potential.

The tunnels are parallel to faults but they don’t cross any faults so that makes the design a little more straightforward than if it were were crossing a fault as certain design features would need to built in to deal with that, Mr. Arakawa noted.

With these segmental liner approach to the design, they are able to withstand major ground acceleration with a major earthquake – ground accelerations that you would see in major earthquake zones in the world like Japan and South America,” he said.

Climate Change Analysis

The next area they looked at was the ability to adapt to climate change. “The state is evaluating the proposed project with certain assumptions with climate change mainly driven by sea level rise assumptions that have been used by the key scientists that look at climate change effects,” he said.   “The sea level rise assumptions are that in the year 2100, there’s the potential that the sea level rise could be as much as 55 inches at the Golden Gate at the downstream end of the estuary. By 2060, that sea level rise could be 18 inches.”

The analysis by the state includes what does this mean to salinity intrusion and to flow, and Metropolitan has done some additional analysis to look at the expected water quality at the north Delta intakes is with those sea level rise assumptions, he said.

3a_Presentation__Page_17He then presented a slide showing how salinity will move up the system under the effects of sea level rise. He noted that the different colors show where the salinity level of 2000 parts per million TDS is expected to be as the sea level rises. “In other venues, we’ve called it X2,” he said. “It’s a way of measuring what the fish agencies refer to as the Low Salinity Zone for fishery habitat. We’re showing these contours in the year 2015, 2025, 2060, and then 2100. These are with average hydrologic conditions, so taking the different hydrologies over many, many years and averaging those. This contour line shows on average where the 2000 parts per million TDS line would be, as compared to where it is in 2015 which is this fine green line. The salinity intrusion as a result of the sea level rise moves salt up into the system, and our concern is how does that affect our export pumps at the southern end of the Delta. This is for average conditions.”

3a_Presentation__Page_18If you look at drier conditions like in a drought, that salinity line goes even further upstream,” he said. “In a drought like this that we’re in today, we’ve seen how salinity has intruded in the Delta with the low hydrology, but with sea level rise, that would occur over a wider range of hydrologies that go beyond just drought conditions. Drought conditions would be the most severe.”

3a_Presentation__Page_19Analysis was done to look at what this means to export water quality at the north intake of the proposed facilities, the south intake where water is currently drawn, and combined salinity as it would be a combination of water from the north diversion and some of the water from the south Delta diversion. “We show the salinity levels for the north intake really not having any measurable impact, both in salinity, total dissolved solids, and bromides in milligrams per liter; there is essentially no measurable change based on the modeling that’s been done. At the south intake, we do see an increase.”

What’s going on with the models is that there is more salinity intrusion as a result of the climate change effects and the sea level rise, but then there’s also more outflow, but even with the higher outflow, the salinity does go up from 301 to 326 by the year 2060, and if you took that out to 2100, it would be more than that,” Mr. Arakawa said. “Similarly, we took the intake from the north and the intake from the south, and we looked at what would be the average quality if those two supplies got blended together, and so the salinity would go from 214 in 2010 up to about 228 in 2060, so having the north intake with the higher quality water certainly does protect you in terms of export quality.”

3a_Presentation__Page_20This is a graphic that is intended to show the effects of climate change as it relates to water supply,” he said, explaining the blue bars represent without California Water Fix, which is about 4.9 MAF of 2015 operations yield between the SWP and the CVP, and 4.7 MAF in the year 2025.

Now this is only with the climate change effects; this is not with any change in regulations,” he said. “In the past we’ve talked to you about the real risk of doing nothing and then out into the future, having less supply because we would expect further regulation of the system; we’ve shown you that supply could be 3.5 MAF if we were to take into account those regulations that the fish agencies have been pursuing in terms of outflows and export curtailments. This depiction here is only looking at the effects of the sea level rise and what it does to salinity and what outflows are necessary in order to combat that salinity; it does not include anything with regard to changed conditions on regulation. As you can see from today, out to 2060, there is a reduction in supply as a result of these sea level rise projections, so water supply today at 4.9 MAF for the two projects would be reduced to 4.4 in the year 2060.”

With the California Water Fix and the proposed operations of those physical systems, the 2025 supply level could be up to about 5.3 MAF, and the 2060 proposed operation up to as much as 5 MAF, so it helps to minimize or reduce the water supply losses that could occur and enhances water supply,” he said.  “So it’s a way of describing the adaptability of this proposed project.”

Revised cost analysis

Mr. Arakawa said that in the past discussion about cost, the figures used were around $14.6 billion for the tunnel, $1.5 billion in operations and maintenance costs over 50 years, and then an additional $900 million for the cost of the additional conservation measures that were part of the habitat conservation plan approach. It totaled about $17 billion in 2012 dollars for the state and federal water contractors.

3a_Presentation__Page_22He then presented an updated set of numbers in 2014 dollars, noting that most of the work has been done in further estimating the conveyance costs; they have looked at O&M costs, but much hasn’t changed there. “We’re showing the mitigation and monitoring costs as a range because those are still being refined,” he said. “With the BDCP, the measure of what was necessary or required was a different measuring stick which was to contribute to recovery. With the proposed project, the requirement is to avoid jeopardy to fish species, so the range in costs depicts what the costs might be for a range of activities that would be part of the mitigation.”

The small increase in total cost reflects a lot of additional work on the cost estimates for the refined conveyance. “It was really the refinements of the intakes and a few other changes to the project that created some savings and so even going from 2012 dollars to 2014 dollars, not much of an increase in the project, and in fact in real dollars, a savings,” he said, noting that updated cost estimates include a 36% contingency because of the complexity of the project.”

Mr. Arakawa said that they plan to do further analysis on the updated cost estimates of what it means to Metropolitan and as compared to other resource options to help make an overall business case.

Draft EIR/EIS comments

The recirculated environmental documents were released back in July for a public comment period extending through October the 30th. “The expectation is that then once those comments are received, the state would then look at how to respond to those comments as well as the comments that came in with the earlier public draft that was out in 2013, and then they would develop a final environmental impact report and impact statement sometime we expect in the first half of 2016,” he said. “So we’re now essentially 6 to 8 months away from potentially seeing a final environmental impact report that the state and the other agencies would be taking action on.”

He said they are currently in the middle of the review process with the recirculated documents, focusing on Metropolitan’s board criteria to make some key points. “We’ve produced comment letters that our member agencies can use and we’ve talked with our member agencies about those sample comment letters; we’ve also provided sample comment letters that they could provide to their constituency or interest groups that could also be filed by the deadline of October 30. Fact sheets have been produced and provided, all of this to help to support the effort of our area to provide meaningful comments on the proposed project by the deadline.”

3a_Presentation__Page_25He presented a list of criteria that the Metropolitan Board approved that provides policy direction on what they would be looking for in a Bay Delta Conservation Plan or in this iteration, the proposed California Water Fix, and said they have been reviewing the project based on these policies.

He then went over the areas of analysis that they are focusing on as they prepare to comment on the proposed project. “There’s an area of policy and that really is tied to the Board’s criteria and making sure that the comments we provide are in the context of what the project would need to be providing in order to meet those board policies,” he said. “Secondly on technical, making sure that the proper analysis on the resource areas and the impacts on the resource areas is being carried out in the environmental document. Third is legal, making sure that the requirements are being proposed in the proposed project are legally ground, that they are the right requirement and making sure that the document is defensible. Fourth is the record, making sure that evidence that’s there to support the proposed project because it will be challenged; so for example, making sure that there’s sound justification and support for science and fishery areas.”

3a_Presentation__Page_28Mr. Arakawa then gave more details on some of the focused comments they were planning on making. “Some of the comments that we are planning to make deal with the benefits of the project and recognizing that when you’re doing modeling analysis, it captures how much water supply in an average year, in different year types, and monthly average periods, but in many ways, there’s the added flexibility of the project to operate around fishery conditions, hydrologic conditions, and to take advantage of situations that occur very quickly. That flexibility of the project also needs to be considered when evaluating the benefits of having a north intake versus just continuing to divert from the south Delta.”

Secondly, we plan to comment on the scientific justification of the operating criteria, making sure that the best available science is included in the record and that the criteria are meeting what we believe are the legal requirements of avoiding jeopardy, and that the justification of those criteria are included in the document,” he said.

Third, the project design and constructability, making sure that the best practices for construction of this kind of project are being included given it’s a very significant project, and making sure that the practices to avoid impacts to the surrounding environment are those that are legally required and feasible given the magnitude of this project,” he said. “And certainly making sure that the project will be able to sustain any challenge.”

Fourth, a science process,” he said. “The flexibility to look at the operations of the project that are in the proposal, deal with what the scientific justification is, and to be able to make decisions along the way as new science becomes available, and to make sure the operations are working as effectively as possible in terms of getting a result that is intended, rather than having an operating requirement that is not having any benefit.”

And last, making sure that the record is clear that the alternatives that have been added as well as the alternatives that are under the initial public draft are all viable, feasible alternatives, and that the latest environmental document is adequate in that regard.

3a_Presentation__Page_26Mr. Arakawa said that the key points in the sample letters say that the system today is unreliable because of regulations and long-term threats, and that the California water fix preferred alternative is an achievable regulatory path which helps with the fishery issues that have been constraining us, as well as emphasize the importance of fixing the Delta for the California economy. Another key point in the letter is that the State Water Project is key to a reliable water supply strategy for Southern California through Metropolitan’s Integrated Resources Plan, and without fixing the Delta, the cost of that would be even greater, he said. The letter for interested third parties is similar, talking about the importance of water supplies to the California economy, the preferred alternative is a workable framework, and that the need is for reliable imported supplies and also local supplies.

Now is the time for a real decision, given that we’ve gone many years without making the tough decisions,” he said.

The comment period will close on October 30 and the state will be working on a final document, he said. Metropolitan staff will return to the committee with the financial analysis and the business case. In 2016, the final EIR/EIS is expected, along with the ROD, the federal permit under Section 7 and the state Section 2081 permit.

So all of the review and work and the financial analysis that will be coming forward with in the coming month and looking at alternative investments, all of that to provide the basis for your decision making as these documents come forward and to be in a position to evaluate the final outcome of the proposed project and determine whether further investments are sound and justifiable,” Mr. Arakawa concluded.

And that’s what I had planned to go over today …

Discussion period
(Slide 22)

Director Fern Steiner directs to slide 22. “Karla Nemeth was down at the Water Authority and she spoke about the fact that there would be absolutely no decision made until all the costs are known, and that every agency has a chance to look at the impact of those costs for that agency as well as for the region. I’m trying to figure out if we have a better timetable now on the costs … before October, a timetable of those costs and then whether there’s going to be enforceable commitments on the state water contractors and the CVP contractors to take some of that water as pay for their share and then what plan there is if someone does default on what they are going to take or decides not to join in, how do we make that up, who makes that up, how is that decided? … the focus for October would be on that cost issue since her comments suggest that we’re a lot closer than we were.”

Mr. Arakawa said that they are approaching that now with the recirculated documents. “We have more refined cost estimates and we have about the best information we’re going to have on the performance of the project that we’re going to get, so we’re now at a point where we can decide, alright, does this project make sense? The State Water Contractors have been talking about resuming discussions between now and the end of the year to go back and pickup where they left off … I think one of the key things that came out of those previous discussions is that the costs are aligned with the benefits so if any cost allocation would be benefits-based, but then really getting down to how is the allocation really going to occur – is it going to be based on contract amount or some other means of allocating the benefits and the costs. The federal contractors at the same time would need to be looking at their financing strategy and how that would fit, and all of this to be in a position so that when we get to early 2016, maybe sometime in the first quarter of 2016. We have at least a State Water Project contractor view of how this might work so we can be in a position to deal with DWR regarding how the contract commitments would work. The hope is that on the federal side, that process also continues and makes progress. We’re also going to need to agree on the split between the state project and the federal project. We generally talked about that in the past and what our assumptions have been in all of our analysis, but in October, we’ll make some assumptions about how those cost splits will occur and what does that mean to Metropolitan.”

These updated costs are reenergizing, even though they really didn’t change,” added Roger Patterson. “State contractors are restarting their conversation. CVP guys seem to be pretty serious now; I talked to the Bureau last week, they are convening a workgroup there, and then there has been an official agreement between DWR and Bureau of Reclamation to do a coordinated operations review, so there’s a review process laid out in the COA. … I think for now, we kind of view it as 50/50, 60/40 split, 55/45 in the middle, so you look at it under any of those, the COA might swing a percent or two, so we’ll try to not be overly precise but bound it in a way that we know that we’ve captured where it might be.”

Slide 20)

Mr. Patterson then refers to bar chart on slide 20. “In the orange bar, I think those did include spring outflow, the south Delta additional restrictions, so I think what Steve was trying to show was good – that is if you just look at climate change and how it could affect things … ”

Mr. Arakawa clarifies, “I think there were regulations included for south Delta exports and certainly the fall X2 outflow requirements. The 5.3 represents what the upper range might be with regard to the spring outflow, but there’s a lower range as well, so that could be somewhere between 4.7 and 5.3. And similarly there would be a range for the 2060. The key to all of this that we would be looking for and would be in our comments is the sound scientific decision making process for resolving what’s really required to protect these fish, how will that be implemented, what kind of decisions would be made, both prior to the operation of the project and leading up to that.

State Water Board update to the Bay-Delta Water Quality Control Plan

Also at the meeting, Metropolitan staff gave an update on the State Water Resources Control Board processes, focusing on the update of the Bay Delta Water Quality Control Plan process.

The California Water Code requires a periodic review of this process, and it charges the State Board to balance competing beneficial uses between M&I water use, agricultural water use, and fisheries uses; and in this balancing act, the State Board has to consider the intersection of flows, water quality, and water rights,” he said.

The Water Quality Control Plan process is moving forward in four phases. The first phase, which is ongoing, is dealing with the San Joaquin River. The second phase, also ongoing, is focusing in on the Sacramento River and the Delta. Phase three will follow at the conclusion of the phase 1 and phase 2 and will be the water rights and implementation. Phase 4, also ongoing, is focusing in on upstream tributaries.

There are several concurrent processes interacting with the State Board’s water quality plan update; some of these processes are a result of the Delta Reform Act of 2009. “The Delta Reform Act set forth the concept of coequal goals,” he said. “In the reform act, it required the State Board to develop flow recommendations for fisheries, and also it required the State Board to adopt appropriate flow criteria prior to approval of the new point of diversion. The act also established the Delta Stewardship Council, that’s the body that produced the Delta Plan in 2013.”

In response to that legislation, the State Board produced its flow criteria report in 2010 in which they suggest flows for fishery protection. “I’d characterize these suggestions as idealized, because they don’t attempt to balance competing beneficial uses and as a result, these recommendations don’t have any regulatory effect,” he said. “However, this is still a very important report. A lot of elements of this report are being discussed in terms of what might be implemented as different pieces of the water quality control plan.”

3b_Presenation_Page_06As part of the phase 2 process, the State Board held a series of workshops with experts on a variety of scientific topics, and they collected volumes of information, a lot of it conflicting. So the Board asked for assistance from the Delta Science Program, who in 2014, produced two reports: one on Delta outflows and one on interior Delta flows. “In all these processes, the Metropolitan staff have been participating,” he said. “We’ve been on expert panels, providing feedback to the State Board and we’ve been doing this in coordination with the state and federal contractors and other stakeholders.

There are currently several key outstanding issues, one of them being concurrent overlapping processes, such as the biological opinions, California Water Fix, and the Delta Stewardship Council’s Delta Plan, he said. “I think the issue is that we would want to see is the water quality control plan process move forward in an integrated fashion with these other processes,” he said. “There’s also concern about the reliability of science and evidence that was presented to the Board – what is good and what should be considered in part of the water plan update. Then lastly, there’s also a concern about potential protracted water rights proceedings as a result of implementing the update in different phases.”

Even though the state board activities have been redirected because of the drought, Metropolitan staff has continued to work on State Board issues, meeting with board members and staff to discuss and work through a lot of the issues, he said. “While we recognize the State Board is required to proceed with the water quality control plan update, we do want to encourage them to keep in mind these different processes that are going on, and that they all move forward in an integrated fashion, particularly coordination with the California Water Fix.

We’re encouraging them to rely on best available science in their decision making,” he said. “We’ve been continuing to work on new scientific developments to supplement the record, and also we are continuing to encourage the idea of balancing competing beneficial uses for any flow criteria that might be considered in part of the new phases.

He said they have been working coordination with several entities, including the State Water Contractors, DWR, the federal contractors, Reclamation, Northern California Water Association, San Joaquin River group, and a variety of power agencies.

He then gave the anticipated next steps. “Right now, because of the drought and priorities being shifted, I don’t have any dates to really give you, but we are expecting the State Board to come out with technical reports and CEQA documents on particularly the phase 1 and phase 2 updates. Staff is continuing to develop science for the decision making and we’re presenting that relevant information to the board, and we’re going to continue to do all these efforts in coordination with state and federal water contractors other stakeholders.”

For more information …


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