WEEKLY WATER NEWS DIGEST for June 9-14: Dams need repairs, but Newsom plans to cut grants in half; Metropolitan places leader on administrative leave; Requiring water users to pay for ecological damage; and more …

A wrap-up of posts published on Maven’s Notebook this week …

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In California water news this week …

These California dams need repairs. But Newsom plans to cut grants in half

Lake Hodges Dam by Matt Topper

“Several dozen dams throughout California could store up to 107 billion more gallons of water if they underwent repairs to fix safety problems. But facing a staggering state deficit, Gov. Gavin Newsom has proposed cutting funding for a dam repair grant program in half this year, while state legislators want the $50 million restored.  California has an aging network of nearly 1,540 dams — large and small, earthen and concrete — that help store vital water supplies. For 42 of these dams, state officials have restricted the amount of water that can be stored behind them because safety deficiencies would raise the risk to people downstream from earthquakes, storms or other problems.  Owned by cities, counties, utilities, water districts and others, these dams have lost nearly 330,000 acre-feet of storage capacity because of the state’s safety restrictions. That water — equivalent to the amount used by 3.6 million people for a year — could be used to supply communities, farms or hydropower. … ”  Read more from Cal Matters.

California’s biggest water agency places leader on administrative leave

The aquifers beneath Los Angeles were one of three sets of aquifers monitored using a new interferometry technique. Credit: Ron Reiring/Flickr, CC BY 2.0

“The board of California’s biggest water agency voted Thursday to place its general manager, Adel Hagekhalil, on administrative leave after a senior employee accused him of cultivating a toxic work environment.  The 38-member board of the Metropolitan Water District of Southern California, which supplies some 19 million Californians in Los Angeles and surrounding areas, also voted to promote chief operating officer Deven Upadhyay to lead the organization on an interim basis.  The decision came after Metropolitan’s chief financial officer and assistant general manager, Katano Kasaine, accused Hagekhalil of harassing her, retaliating against her for sharing her concerns about the budget process and creating a hostile work environment, in a letter obtained by POLITICO. … ”  Read more from Politico.

Reforming California’s financial penalties for water theft will create an effective deterrent

Professor Richard Frank writes, “In a Legal Planet Post earlier this week, I recounted the saga of how federal prosecutors recently secured the criminal conviction of Dennis Falaschi, the former San Joaquin Valley water district general manager who oversaw the decades-long theft of millions of gallons of publicly-owned water from California’s Central Valley Project.  That successful prosecution certainly qualifies as a good news story on the environmental enforcement front. … Which brings us to another California example of egregious theft of the public’s precious water supplies for private gain, to the detriment of other, law-abiding water users, the public and the environment.  In November 2022, former Sacramento Bee reporters Dale Kasler and Ryan Sabalow wrote in a Bee article that earlier that year–during the height of an intense, multiyear California drought–farmers and ranchers in rural Siskiyou County openly defied a “curtailment order” that had been lawfully adopted by California’s State Water Resources Control Board. … ”  Read more from Legal Planet.

The end of El Niño might make the weather even more extreme

“Summers keep getting hotter, and the consequences are impossible to miss: In the summer of 2023, the northern hemisphere experienced its hottest season in 2,000 years. Canada’s deadliest wildfires on record bathed skylines in smoke from Minnesota to New York. In Texas and Arizona, hundreds of people lost their lives to heat, and in Vermont, flash floods caused damages equivalent to those from a hurricane.  Forecasts suggest that this year’s upcoming “danger season” has its own catastrophes in store. On May 23, scientists from the National Oceanic and Atmospheric Administration announced that the 2024 Atlantic hurricane season could be the most prolific yet. A week earlier, they released a seasonal map predicting blistering temperatures across almost the entire country. … ”  Read more from Wired Magazine.

Requiring water users to pay for ecological damage: A conversation with environmental lawyer Karrigan Börk

“Water diversions can harm aquatic ecosystems, riparian habitat, and beaches fed by river sediment. But the people who use water don’t bear the cost of this ecological damage.  “The public pays for it,” says Karrigan Börk, a University of California, Davis law professor who has a PhD in ecology. He is also Co-Director of the California Environmental Law and Policy Center and an Associate Director of the UC Davis Center for Watershed Sciences.  Börk presents a new solution to this problem in a recent Harvard Environmental Law Review paper. His idea was sparked by the fact that developers are required to help pay for the burden that new housing imposes on municipal services.  To likewise link water infrastructure and diversions with their costs to society, Börk proposes requiring water users to pay towards mitigating the environmental harm they cause. This work won the 2024 Morrison Prize as “the most impactful sustainability-related legal academic paper published in North America” published in 2023.   To learn more, Robin Meadows spoke with Börk about how this solution would work, examples of similar approaches already established in the Western water world, and ways of putting this approach in place in California. This conversation has been edited for conciseness and clarity…. ”  Continue reading at Maven’s Notebook.

Report shows some progress on groundwater storage

A drone photo of water diverted onto a newly constructed groundwater recharge basin at Mountain View and Temperance near Selma in Fresno County, California. Photo taken May 13, 2024 by Xavier Mascareñas / DWR

“The good news is that the San Joaquin Valley has managed to store a little more groundwater since the drought of 2016. The bad news is that it is hard to keep account of what’s working and what’s not.  On Tuesday, the Public Policy Institute of California, a nonprofit policy research organization, released an update report on the replenishment of groundwater in the San Joaquin Valley, one of the areas of the state that is heavily dependent on groundwater. The report also identified those basins best suited to accept water recharge operations, with the highest number being in the eastern and southern regions of the valley.  In late 2023, following a very wet winter and spring, the institute surveyed recharge activities in local water agencies. … They found a 17% increase in the total water volume that was recharged in the valley, including areas that use only groundwater. … ”  Read more from SF Gate.

Kings County Farm Bureau taking on State Water Board over SGMA probation

“Kings County Farm Bureau (KCFB) is leading an action against the State Water Resources Control Board (SWRCB) and its administration of the Sustainable Groundwater Management Act (SGMA). The legal challenge was filed after the Tulare Lake Sub-basin was placed on probation. However, KCFB Executive Director Dusty Ference explained that it is more than a local concern they are taking on.  “This is not a Kings County issue right now. This is not a Tulare Lake subbasin issue right now. This is a California issue, and we need support to keep this legal fight moving forward as aggressively as we can,” Ference noted. “The Tulare Lake subbasin is one of several subbasins to be considered for probation. There are several probationary hearings scheduled for the rest of this year and next year, where the board will consider placing other subbasins on probation.” … ”  Read more from Ag Net West.

Sparks fly as Tule basin agency is accused of being “unable and unwilling” to curb over pumping

“Fireworks were already popping between board members of a key Tulare County groundwater agency recently over an 11th hour attempt to rein in pumping in the severely overdrafted area.  The main issue at the Eastern Tule Groundwater Sustainability Agency (GSA) meeting June 6 was whether to require farmers in subsidence prone areas to install meters and report their extractions to the agency, which is being blamed for almost single handedly putting the entire subbasin in jeopardy of a state takeover.  “I don’t know why we’re sitting here massaging this thing knowing damn well the state told us to do this,” said Eastern Tule board member Matt Leider of requiring the meters.  But fellow board member Eric Borba pooh poohed the need for urgency, suggesting the board take things “one step at a time.” … ” Read more from SJV Water.

Defining the ‘significant and unreasonable’ inadequacies in subbasin GSPs

“Despite varying interests and distinct stakeholder needs, one thing Groundwater Sustainability Agencies can collectively agree on is the need to avoid a probation determination from the State Water Resources Control Board.  Of the six critically overdrafted basins in the Central Valley, only the Tulare Lake Subbasin has officially been placed on probation. While the six basins cover different areas with unique water needs and landowner interests, there are several commonalities in the deficiencies the SWB found within the separate groundwater sustainability plans.  State Water Board staff has released three probationary hearing draft staff reports for the following basins — Tulare, Tule, and Kaweah. The subbasin GSPs share three specific inadequacies: chronic lowering of groundwater levels with insufficient Sustainable Management Criteria, continued land subsidence, and further degradation of groundwater quality. … ”  Read more from Valley Ag Voice.

Western agricultural communities need water conservation strategies to adapt to future shortages

Farm fields outside of Yuma, Arizona.

“The Western U.S. is heavily reliant on mountain snowpacks and their gradual melt for water storage and supply, and climate change is expected to upend the reliability of this natural process. Many agricultural communities in this part of the country are examining ways to adapt to a future with less water, and new research shows that a focus on supplementing water supply by expanding reservoir capacity won’t be enough to avert future water crises.  Led by scientists at the Desert Research Institute (DRI), the study published June 11 in Earth’s Future. By identifying agricultural communities considered at-risk from looming changes in snowfall and snowmelt patterns, the researchers found that water conservation measures like changes in crop type and extent were more stable adaptive strategies than changes to reservoir capacity. By the end of the century, many areas could have less than half the water they have historically relied on to refill their reservoirs, but changing the types and extent of their crops could help by restoring an average of about 20% of reservoir capacity. … ”  Continue reading at Desert Research Institute.

On farms, ‘plasticulture’ persists

Workers lay down plastic while prepping field for cantaloupes in the Imperial Valley.

“In 1948, E.M. Emmert, a horticulturist at the University of Kentucky, was tinkering around with how to build a cheap greenhouse. He decided to use polyethylene sheets in lieu of the glass sides, bending the plastic film around a wooden frame. The plants thrived in the new environment; the plastic let in enough light while trapping in warmth.  This is commonly regarded as the first introduction of plastic into agriculture, a move that would transform modern farming—and inadvertently deposit an untold amount of plastic in the soil.  In the decades that followed, this cheap, pliant material spread through farms across the U.S. and world, becoming so widely used that plastics in agriculture gained its own name: plasticulture. … ”  Read more from Civil Eats.

RELATED: NOTEBOOK FEATURE: Are farm fields a hidden source of microplastics?

This California ‘shipwreck,’ beloved but rotting, has got to go, officials say

“It once was beautiful, the S.S. Point Reyes, even as it slowly rotted on the banks of Tomales Bay.  But now, its hull is shattered; its innards, rusty and charred. Moss clings to its damp wooden planks, and graffiti mars its chipped paint. It lists precariously toward its starboard side.  The abandoned fishing boat — stuck on a mudflat in the tiny town of Inverness since the late 1990s, residents say — found its fame long after its working days were done.  Its resting place was pinpointed on Google Maps as “Point Reyes Shipwrecks,” proving irresistible for travelers on nearby Highway 1. It was geotagged on Instagram, where it became the muse of multitudes of cellphone photographers. … It has been beloved and abused. And its days appear to be numbered. … ”  Read more from the LA Times.

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In commentary this week …

Investing now to keep Valley safe from megafloods

Senator Alvarado-Gil, Assemblyman Heath Flora, and Assemblywoman Esmeralda Soria write, “We all know it. You shouldn’t wait to close the barn door until after the horse has bolted.  That’s an important lesson for Central Valley communities today. California didn’t experience floods this past winter like we did in 2023. But given that the legislature is writing a bond now, this is the time to speak up to keep our communities safe from catastrophic flooding in the future.  A year and a half ago, the town of Planada was hit by a devastating flood. When a debris-clogged Miles Creek overflowed, the resulting flood hit like a gut-punch. UC Merced researchers found that 83 percent of all households suffered, and many lost everything.  “These were more than houses,” one anguished resident told the media, “they were symbols of a lifetime of hard work.” … ”  Read more from Maven’s Notebook.

Editorial: Further analysis of Delta tunnel costs should be required

The Livermore Independent writes, “A recent benefit-cost analysis of the Delta Conveyance Project (DCP) excludes the possibility of cost overruns, among other concerns. Therefore, it adds little to the discussion of whether the megaproject is a prudent solution to the state’s water difficulties.  The project, also known as the Delta Tunnel, plans to divert the Sacramento River from a point about 15 miles south of Sacramento and carry the water through a new 45-mile long underground tunnel to the Bethany Reservoir before integration with the rest of the State Water Project, the system of reservoirs and aqueducts that provides water to some 27 million people in the state.  A May 16 report, prepared by the Berkeley Research Group and released by the Department of Water Resources, estimated the avoided costs of the tunnel  — costs that would otherwise be incurred because of seismic and salt-related damages to urban and agricultural water supplies — to be some 2.2 times the cost to build the tunnel.  But costs for large infrastructure projects tend to balloon as they are built. … ”  Continue reading from the Livermore Independent.

Comment letter on Delta Conveyance Project benefit-cost analysis

Dr. Jeff Michael, Professor of Public Policy at University of the Pacific McGeorge School of Law, writes, “On Monday, the Department of Water Resources Director and consultants will be presenting their latest cost-estimate of the delta tunnel and a recently released benefit-cost report to the Metropolitan Water District (MWD).  Their presentation is posted now, and it is an all positive promotional pitch that does not seriously engage with the financial and environmental issues with the estimated $20 billion project. The presentation also conceals some of the extreme assumptions that are used to inflate the benefits of the project, and makes a misleading and inaccurate cost comparison of DCP water to alternative supplies. … ”  Read more from the Valley Economy blog.

Where can Californians turn when their water is brown? LA County saga shows the way

Oralia Avila. who works in customer services for Suburban Water Systems and lives in unincorporated Los Angeles County, writes, “Imagine growing up in a home where tap water consistently runs a stomach-churning brown, sometimes with an odor.  You hate to bathe in it, and you certainly aren’t going to drink it. You’re not in some remote hinterland, either. You’re in Los Angeles County.  Brown tap water was a feature of my childhood. No one outside our poorly managed and financially challenged Sativa Water District in Compton and Willowbrook seemed to understand or care that we feared our own water.  My mom purchased bottled water for drinking and cooking, shouldering the cost like an extra tax. Still, we had to climb into the murky stuff in the bathtub. Sometimes our clothes came out of the wash more stained than when they went in. … ”  Read more from Cal Matters.

How California can rewrite the extraction business model and boost Salton Sea communities

Silvia Paz, executive director of Alianza Coachella Valley, writes, “California is at a policy and fiscal crossroads. It must decide whether to rewrite the extraction business model to benefit impacted communities, or to continue with the traditional model that causes unmitigated environmental and economic injustices.  The Salton Sea region is facing economic pressure to become a substantial domestic supplier of lithium, placing greater challenges on lower-income communities that already face significant disparities – yet contribute so much to the prosperity and quality-of-life of others. Without meaningful investment, these communities will fall further behind as their needs are sidelined in the rush for lithium development.  This is a story all too real to the farm laborers and low-wage tourism workers who call this region home. … ”  Read more from Cal Matters.

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In regional water news this week …

Irrigators clash with US government and Yurok Tribe over Klamath water rights at Ninth Circuit

“The Klamath Water Users Association, along with the U.S. Bureau of Reclamation and other plaintiff appellants asked a Ninth Circuit appeals panel Wednesday morning to reverse summary judgment from a case that confirmed the bureau and other actors must comply with the Endangered Species Act when operating the Klamath Irrigation Project. … In a victory for the fish and the tribe, U.S. District Judge William Orrick ruled in 2023 that the federal government must follow its own laws, such as the Endangered Species Act, and isn’t obligated to comply with an Oregon order to stop releasing water from the Upper Klamath Lake, which is the source of the Klamath River.  Orrick’s ruling upheld the notion that irrigators’ rights come after the bureau’s obligations to protected fish species and tribal rights in the Klamath Basin.  At the Ninth Circuit hearing on Wednesday, Brittany Johnson, counsel for the Klamath Water Users Association, which represents ranchers as well as water districts in the region, asked the panel for a “clear declaration” that the bureau does not have authority to curtail the delivery of water from the project for irrigation. … ”  Read more from the Courthouse News Service.

Klamath Basin leaders call for full water allocation

The Klamath River in winter near Happy Camp, California, also known as the Steelhead Capital of the world. Photo by Matt Baun/USFWS.

“Due to significant economic impacts to farmers and others in the Klamath Basin, county leaders are urging water officials to provide a full water allocation to irrigators this year.  In a statement, Klamath Water Users Association Executive Director Paul Simmons said inadequate water allocations have real consequences for working families and communities.  “We join supervisors from Siskiyou and Modoc counties and the commissioners from Klamath County in calling on federal agencies to take immediate action to provide a full supply for the 2024 water year and adequate irrigation supplies into the future,” he said.  “At all levels—from the top down—we need to respect the economic and socioeconomic realities of those who depend on the Klamath Basin for our livelihoods,” Simmons added. … ”  Read more from Ag Alert.

Making a major river corridor more fish-friendly

“The fish travelling the Sacramento River between the upper Sacramento Valley and the Pacific Ocean contend with a variety of perils as they make the journey.  The river’s path has been highly modified and separated from its historical floodplain for more than a century, enabling homes and farms to exist at the very edges of the levee system.  Altered flows, fluctuating water temperatures, diminished food and habitat and losses from predation mean the threatened and endangered Chinook salmon runs face tremendous odds in surviving their life cycle journey.  Scattered along the river are intakes, large and small, that divert water for agricultural use and valley communities. Unscreened, these structures can take their toll by sending fish on a one-way trip out of the river. It’s a problem Reclamation and its local, state and federal partners have been working to solve for 30 years. … ”  Read more from the Bureau of Reclamation.

Remarkably average water year means better conditions for fish in the Lower American River

“Spring and early summer are a crucial time of year for the American River: It’s when we find out how much Sierra Nevada snowmelt will be available to fill Folsom Reservoir, and what that means for keeping river temperatures cool for imperiled salmon and steelhead.  While many Californians are getting used to the idea that rapidly changing climate conditions have made “extreme” the new normal, this year is unusual in a mundane way:  It’s average! The 2023-2024 winter produced “nearly average” conditions, historically speaking, in the American River watershed, said Ashlee Casey, senior engineer at the Water Forum. That’s unusual because “average” is rare in California weather patterns and will continue to be so in this era of climate change when we are expected to swing dramatically between wet and dry conditions. … ”  Read more from the Water Forum.

Napa Valley has lush vineyards and wineries – and a pollution problem

Photo by Daniel Salgado on Unsplash

“Famous for its lush vineyards and cherished local wineries, Napa valley is where people go to escape their problems.  “When you first get there, it’s really pretty,” said Geoff Ellsworth, former mayor of St Helena, a small Napa community nestled 50 miles north-east of San Francisco. “It mesmerizes people.”  What the more than 3 million annual tourists don’t see, however, is that California’s wine country has a brewing problem – one that has spurred multiple ongoing government investigations and created deep divisions. Some residents and business owners fear it poses a risk to the region’s reputation and environment. At the heart of the fear is the decades-old Clover Flat Landfill (CFL), perched on the northern edge of the valley atop the edge of a rugged mountain range. Two streams run adjacent to the landfill as tributaries to the Napa River.  A growing body of evidence, including regulatory inspection reports and emails between regulators and CFL owners, suggests the landfill and a related garbage-collection business have routinely polluted those local waterways that drain into the Napa River with an assortment of dangerous toxins. … ”  Read more from The Guardian.

Grand jury report faults San Francisco for inadequate climate threat planning

“As climate change unleashes ever-more powerful storms, worsening floods and rising sea levels, San Francisco remains woefully unprepared for inundation, a civil grand jury determined in a report this week.  The critical assessment — written by 19 San Franciscans selected by the Superior Court — found that the city and county lacked a comprehensive funding plan for climate adaptation and that existing sewer systems cannot handle worsening floods. Among other concerns, the report also concluded that efforts toward making improvements have been hampered by agency silos and a lack of transparency.  Members of the volunteer jury serve yearlong terms and are tasked with investigating city and county government by reviewing documents and interviewing public officials, experts and private individuals. … ”  Read more from the LA Times. | Read via Yahoo News.

State allegedly ghosted Merced’s attempts to get permission to clear creeks for months before the floods

A flooded street in Merced County on Jan. 11, 2023. Photo: Andrew Innerarity / DWR

“Evidence is stacking up against the state in one of multiple lawsuits over last year’s devastating floods in Merced County. One of the most stunning new pieces of evidence is a string of 12 emails from Merced County staff that went ignored by the state for more than four months before last year’s floods.  The lawsuit was filed against the California Department of Fish and Wildlife (CDFW) on behalf of the City of Merced, a local elementary school and 12 agricultural groups. All the plaintiffs took significant damage from flooding after water backed up in clogged waterways and broke through, or overtopped creek banks and levees.  The flooding came primarily from Bear Creek and Black Rascal Creek, both of which have flooded before. Flooding from Miles Creek also damaged nearly every home in the small, rural town of Planada. … ”  Read more from SJV Water.

Madera farmers and groundwater agency in limbo waiting for court decision on fees

“The end of a two-year legal fight over who should pay, and how much, to replenish the groundwater beneath Madera County could be in sight.  A motion to dismiss the lawsuit by a group of farmers against the county is set to be heard June 18.  The outcome could determine whether Madera County, which acts as the groundwater sustainability agency (GSA) for hundreds of thousands of acres across three water subbasins, can finally move forward on a host of projects to improve the water table per the Sustainable Groundwater Management Act (SGMA).  From the farmers’ point of view, the outcome of this case could make or break their farms, some that have been in their families for generations. … ”  Read more from SJV Water.

Eastern Tule GSA approves meters for subsidence management area

“In an effort to possibly head off being placed on probation by the state the Eastern Tule Groundwater Sustainability Agency, which covers Southeastern Tulare County, voted to begin using meters to monitor groundwater pumping in the area in which most of the groundwater pumping occurs, SJV Water reported.  The ETGSA board by a 6-0 vote approved the measure to begin using meters in its subsidence management area. It’s a last ditch effort to show the state the agency continues to work to meet the requirements of the Sustainable Groundwater Management Act to reduce the pumping of groundwater. … ”  Read more from the Porterville Recorder.

Report finds Kern leads valley in aquifer recharge, but that more could be done

“Kern County continued last year to lead the San Joaquin Valley in groundwater recharge, according to a new report that points to increased support for the activity as a way of helping rebalance the region’s overdrafted aquifers.  Surveys by the Public Policy Institute of California found that water agencies within the Kern River Basin stored a combined 2.9 million acre-feet of water, accounting for a little more than half of the valley’s total recharge volume in the historically wet year that was 2023. In a few respects, the county’s leadership is not surprising: Not only did Kern lead in 2017 — another big water year that followed a series of exceptionally dry ones — but it is home to a series of longstanding groundwater banks, and its physical setting is well-suited to aquifer recharge, the PPIC reported. … ”  Read more from the Bakersfield Californian.

Study says water transfer deal is raising dust and draining the Salton Sea

“The Salton Sea is a terminal saltwater lake. It’s a flooded basin with no natural outlet, similar to the Great Salt Lake or the Aral Sea. And the Salton Sea is shrinking.  One of the reasons for that is the Imperial Water Transfer deal that has brought hundreds of thousands of acre feet of water to San Diego over the last two decades. The deal, signed 21 years ago, meant the Imperial Valley began transferring excess water from the valley’s farm fields to San Diego’s water taps.  That meant a lot less farm runoff that had been sustaining the Salton Sea.  San Diego State University economics professor Ryan Abman said the biggest effects of that conservation plan were seen about eight years into the agreement.  “So really, after 2011, we see a noticeable increase in the rate of decline of the water level and that leads to an increase in the increased rate of playa exposure. So more of this dust-emitting surface is being exposed every single year,” Abman said. … ”  Read more from KPBS.

The future of the Colorado River won’t be decided soon, states say

“The future of the Colorado River is in the hands of seven people. They rarely appear together in public. This week, they did just that – speaking on stage at a water law conference at the University of Colorado, Boulder.  The solution to the Colorado River’s supply-demand imbalance will be complicated. Their message in Boulder was simple: These things take time.  “We’re 30 months out,” said John Entsminger, Nevada’s top water negotiator. “We’re very much in the second or third inning of this baseball game that we’re playing here.” … ”  Read more from Aspen Public Radio.

Oops! 40,000 acre-feet of water slipped through the cracks at Lake Powell

“As the drought-strapped Colorado River struggled to feed water into Lake Powell to keep its massive storage system and power turbines from crashing in 2021 and 2022, the U.S. Bureau of Reclamation, its operator, was scrambling to bring in extra water from Flaming Gorge and Blue Mesa reservoirs.  Since the return of healthier flows in 2023, water levels in Flaming Gorge and Blue Mesa have been restored, as required under a 2019 Colorado River Basin drought response plan.  But the subsequent shifting of water in 2023 to balance the contents of Powell and Lake Mead, required under a set of operating guidelines approved in 2007, resulted in an accidental release of 40,000 acre-feet of water that will not be restored to the Upper Basin because it is within the margin of error associated with such balancing releases, according to Alex Pivarnik, supervisory hydrologist with Reclamation’s Upper Colorado Basin Region. … ”  Read more from the Colorado Sun.

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Announcements, notices, and funding opportunities …

NOTICE: State Board AHO releases procedural ruling and amended notice of public hearing for Sites Reservoir water right application

OPPORTUNITY TO COMMENT: Draft Reclamation 2025 Annual Work Plan for the Lower San Joaquin River

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