A Bold New Approach to Ecosystem Management

A Bold New Approach to Ecosystem Management

For decades, California’s water policy has been based on a false choice – choose healthy ecosystems with abundant fish and wildlife or choose water for people, farms and other purposes. And for decades the policies based on this choice have utterly failed all water users. Fish continue to decline; wildlife refuges suffer and cities and farms struggle to meet their needs.

Not willing to accept a system that forces Californians to pick winners and losers, scientists, farmers, conservationists, fishing interests and others have been working together to find creative solutions that work for all. A host of projects throughout the state have been launched with some impressive results all leading to the same conclusion: we must move away from thinking that says the only measure of a healthy ecosystem is the amount of water in our rivers and embrace a holistic approach that considers an array of factors.

Now, in an exciting new report, the Public Policy Institute of California (PPIC) details recommendations from prominent water scientists embracing this new approach to policy focused on comprehensive solutions.

These scientists discuss specific benefits of looking at the health of the eco-system as a whole rather than focusing on individual components. And most importantly, the paper recommends that current science guide future policy rather than blind adherence to past practices. In a separate article, Jay Lund, professor of watershed sciences at UC Davis says the current water-only focus represents, “a sort of a scientific laziness.”

And this is not just scientific theory. Across the state, diverse interests are working together to create and implement solutions to water problems that have produced concrete results demonstrating the validity of the holistic approach. A few examples include:

  • In Redding, farmers, environmental groups and government agencies are creating safe habitat to protect salmon from predators. It helps the salmon survive and frees up water for other uses. A healthy ecosystem makes the whole river better for everybody.
  • In the San Joaquin Valley, Del Puerto Water District is building a first-of-its-kind recycling project that addresses agricultural and wildlife refuge water supply shortages utilizing recycled water. Use of the recycled water helps reduce urban discharge into the San Joaquin River, groundwater pumping and reliance on the Delta while freeing up other water for the refuges.
  • The San Francisco Public Utilities Commission (SFPUC) working with other water interests along the Tuolumne River has put into practice the kind of plan the PPIC report discusses. It uses a comprehensive approach that manages fish habitat, predators, and water flow in order to support the fish population while maintaining water supply reliability for all of its other users – farm, city, recreation and environment.
  • Farmers in the San Luis & Delta-Mendota Water Authority are helping fund one of the most exciting projects so far. Known as the Nigiri Project, it connects the fish food in flooded Sacramento Valley rice fields to the river where fish can access it and thrive.

These are just a few examples of projects underway that show what can be accomplished when water users side-step our broken water management system and collaborate on innovative, science-based solutions. We applaud the PPIC report and urge the state water bureaucracy to either lead us towards the comprehensive approach described or let progressive conservationists, farmers, scientists, cooperative agencies and fishing interests take the lead and find solutions that work for all California water users.

The System is Broken

Over the past 25 years there has been considerable controversy over allocation of the Bureau of Reclamation’s Central Valley Project (CVP) water supplies. Allocation amounts vary wildly with one routinely getting 100% while others receive dramatically less. Water project opponents say that’s the result of our water rights system but those rights haven’t changed and the water service contractors are worse off than they have ever been.

Going back to 1994 South of Delta water service contractors received, on average, a 43 percent initial water allocation. But if you specifically compare years similar to 2018, where we have in excess of 4.8 million acre-feet of water stored in Shasta, Folsom and the federal share of San Luis Reservoir, the story is much different. In years like 2018 the initial allocation was on average 60 percent, not the 20 percent announced by Reclamation on February 20. On the Eastside, Friant Class I allocations are just 30 percent. Upon learning of the meager allocations Westlands Water District board member Todd Neves questioned how farmers can possibly plan based on such a paltry initial allocation.

So, what’s going on? Reclamation says its conservative allocation announcement is due to uncertainty on how much cold water will be available in Shasta this year for salmon in the Sacramento River. The CVP was designed and built in large part for the purpose of supplying water to farmland but it is now being managed first and foremost for the benefit of fish. That would be fine if these management decisions, mostly driven by the National Marine Fisheries Service, resulted in more fish but that’s not the case. Salmon populations have plummeted along with the reliability of the CVP to deliver water to Sacramento and San Joaquin Valley farms.

What’s the solution? Invest more in the science and the kinds of projects that ARE having a positive impact on salmon populations. The Nigiri Project, a public/private partnership, is showing that flooded rice fields can work for both fish and agricultural water users. Smart predator control and improved salmon habitat in the Delta can help baby salmon make it safely to the ocean where they can grow and return to spawn as adults. The Bureau of Reclamation must consider its obligation under the WIIN Act, which requires the agency to use a science-based approach instead of intuition with regard to water management. Building more water storage projects to help meet California’s future water needs is critical in light of the volume of existing storage that has been lost to serve new demands that were not part of the plan when the CVP was envisioned and built. And encouraging project operators to use the tools and legislation created for flexibility in ensuring that all areas of water management include a balanced approach. After all, water is the foundation for safe, clean and a healthy food production of our nation’s best food and fiber products.

No Chicken Little, the Sky is Not Falling

No Chicken Little, the Sky is Not Falling

A quick scan of California news over the last few weeks could lead the casual reader to conclude that smelt, salmon and other species are days from extinction and the only thing that will save them is taking water from people, farms and other environmental uses and pumping it to sea as the lone savior of these struggling fish populations. This myopic view helps no one, including fish. That’s why a new plan to review Central Valley Project operations can provide multiple benefits for farms, municipal and industrial users, and iconic fish species, including the Chinook salmon.

While we can all agree the rules governing water use in California are not working for any of us – urban, farm or environmental users – we believe the best path towards balanced policy that benefits all is a calm examination of current scientific research pointing to exciting new possibilities.

Once case in point is Winter-run Chinook salmon. These wily salmon have proved themselves smarter than all of us.

While many observers have hysterically pronounced the salmon had disappeared and immediately started pointing fingers at other water users, scientists at UC Davis were busy making an exciting discovery. In order to adapt to warmer water and some man-made flood control measures that helped make their path to the ocean more difficult, they took matters into their own fins and have been make stops in safer estuaries along the journey. In other words, they couldn’t be found because we weren’t looking in the right places. Providing safer habitat is one thing current science tells us can help increase their numbers.

Another thing to keep in mind is this: When you withhold water from the Central Valley you not only jeopardize healthy food production and urban uses, you hurt the environment as well. Few people realize that federal, state and private lands in the Central Valley together make up the largest contiguous freshwater wetlands remaining in California and the second largest contiguous wetlands in the Continental United States. These wildlife refuges are home to birds, animals, plants and fish that depend on this water to survive. “Environmental” use of water in California is much broader than some would lead you to believe and all environmental uses need a voice at the table. If we make policy based on outdated information we may end up only marginally helping fish and doing serious damage to other endangered species as well as farms and people.

We support the current environmental review governing use of Central Valley Project water and believe that current science and calm logic can lead us to water policy that benefits all California water users. There’s more than one way to grow a fish.

Salmon can thrive without State’s unimpaired flow plan

Peter Fimrite’s story in the San Francisco Chronicle (http://bit.ly/2AOyfBh) brings a positive message about higher numbers of this year’s Fall run Chinook salmon on the Mokelumne River. According to Fimrite, near record numbers of fish have returned, thanks to efforts behind stream bed and habitat improvements.

Mokelumne River

Interestingly, this success has been achieved without a massive increase in flows on the river, such as the plan proposed by the State Water Resources Control Board for the Stanislaus, Tuolumne, Merced and Sacramento rivers. Can there be any better evidence that habitat improvements are a better solution than flushing a lot of water down a river under the assumption that more water equals more fish?

The returning salmon are three years old. That means they started their journey as youngsters in 2014, a critically dry year and right in the middle of the driest period in California history. How do you explain the disconnect between big salmon numbers and low river flows? Maybe it’s not the amount of water so much as it is the quality of habitat the salmon have in the river.

Updating the Bay-Delta Water Quality Control Plan

SWRCB updating Bay-Delta Water Quality Plan and SED

In 2016, California’s State Water Resources Control Board (SWRCB) began the process of updating the Bay-Delta Water Quality Control Plan. The public comment period officially closed at noon on March 17. (Read CFWC’s comment letter here.)

During that time, loud and sustained objections to the proposed policy have been raised.

Flow-based approaches in the past have failed

By focusing solely on the amount of water flowing through the river, the SWRCB staff proposal is relying on outdated science that has been proven ineffective at halting the decline of endangered fish populations. Incredibly, if adopted in its present form, the policy will also have a devastating impact on drinking water, sanitation needs, food production, groundwater, the economy and jobs for people stretching from the Northern San Joaquin Valley throughout the Bay Area.

That’s why this proposed regulation is opposed by schools, health departments, farmers, cities, economic development officials, and water agencies throughout the state including the Central Valley, Bay Area, Central Coast, Los Angeles, and the Inland Empire.

Opposition to SWRCB plan is growing

Opposition to this wrong-headed policy has continued to grow and now includes statewide groups like the California Chamber of Commerce and the Association of California Water Agencies, regional organizations such as the Orange County Business Council as well as hundreds of individual Californians. Not even a drought-busting water year like this one could diminish the impacts of this unequivocally bad policy.

Holistic Approach with Functional Flows, not SED Approach

What we need instead is a comprehensive, outcomes-driven, science-based, collaborative approach that includes “functional” flows as well as non-flow solutions that contribute real benefits to ecosystem recovery.

As the Board goes behind closed doors to deliberate the draft proposal we would urge them one more time to listen to the voices representing millions of Californians opposed to the plan and open the door to collaborating on a real solution.

Reactions to State Board Unimpaired Flows Action

Reactions to State Board Unimpaired Flows Action

On September 15, the State Water Resources Control Board released an updated proposal for the Bay Delta Water Quality Plan, expanding the pursuit of increased flow in it’s approach for addressing species decline in the Sacramento-San Joaquin River system.

“If implemented, the State Water Board’s rule will have a devastating impact on drinking water, sanitation needs, food production, the economy and jobs for people stretching from the Northern San Joaquin Valley throughout the Bay Area. That’s why this regulation is opposed by schools, health departments, farmers, Latinos, cities, economic development officials and more,” said Mike Wade, executive director of the California Farm Water Coalition.

Water Resource Control Board President Felicia Marcus in an Op-Ed in the Sacramento Bee on September 15, 2016 remarked that-

“sometimes our rivers are asked to do too much. And then it is the State Water Board’s duty to balance water use among the many people and wildlife that are dependent on the rivers. This is now happening with the San Joaquin River. It is the longest river in California, the second largest in the state, and a critical piece of the Bay Delta puzzle. The San Joaquin is an overburdened river.”

Marcus goes on to say that the State Board will “be listening for people’s best thoughts and proposals in the coming weeks and months before making our decisions.”

But in a joint response by Modesto Irrigation District and South San Joaquin Irrigation District issued September 15, 2016, Oakdale Irrigation District General Manager Steve Knell noted that

“these plans fail to consider new science that is pointing to holistic approaches to addressing multiple stressors that affect fish populations, not just flow”

despite the numerous attempts by community leaders and water experts to ensure that the Board was aware of the multiple stressors affecting endangered fish and the Delta ecosystem, the Board continues to pursue an approach that has failed to achieve improvements in fish populations for over 20 years. The failure of flushing more and more water to the ocean is well documented, says Wade-

“The reason they cannot demonstrate benefit is because science clearly shows that decades of releasing water to the ocean has failed to halt the decline of Chinook salmon and Delta smelt. It is time to stop relying on failed strategies and move on to solutions that science tells us will help.”

Adding to the ire of affected communities, Knell noted that despite Board member commitments to listen to the public,

“Not a single public meeting ever was held in San Joaquin, Stanislaus or Merced counties.”

Representing 27 different cities, counties, school departments, chambers of commerce, water districts and farm bureaus, A Multi-County Coalition issued a response to the action calling for better analysis of available modern science, and demanded an improved process that incorporates feedback from impacted communities and stakeholders, as well as mitigation for the impacts on disadvantaged communities from any Water Resources Control Board action. The Coalition reports that the action-

“If implemented, the proposal shuts down any hope of economic growth in this multi-county region, eliminates swaths of agricultural employment, thwarts job creation and creates enormous funding challenges for schools, cities, public health, law enforcement and other essential public services.”

“It is unbelievable that our government would propose regulations that their own staff say will put farms out of business, reduce water supplies and have negative impacts on groundwater. Yet they can’t tell us what, if anything, this will do to protect the environment.” said Mike Wade, executive director of the California Farm Water Coalition.

Response to the State Water Control Board’s Water Quality Control Plan

This project includes the development of additional water that can be used for irrigation and wildlife enhancement purposes and to improve groundwater recharge in the area.

The State Water Resources Control Board has released its Water Quality Control Plan which, if implemented, will cause significant harm to California residents without quantifying any specific environmental benefits.waterboards_logo_high_res

In taking this step, Felicia Marcus, the Board’s Chairwoman noted that San Joaquin River flows have not been updated since 1995. We fully agree it’s time that state policy be aligned with current science which is why we find this proposal so wrongheaded. Science clearly shows that decades of releasing water to the ocean has failed to halt the decline of Chinook salmon and Delta smelt. 

And yet, the Board proposes to flush out to sea enough water to serve the domestic needs of 2 million Californians or produce almost 5.8 billion salads. If we know twenty years of failed efforts won’t do the job, why not try some of the proposed alternatives first? 

Chairwoman Marcus goes on to say that “The issue is not about choosing one over the other. It is about sharing the river because Californians need and want healthy communities, healthy agriculture and a healthy natural environment.” We couldn’t agree more. The only way farmers survive is by being good stewards of the land, and we’re not alone. We hope that the Board will listen to the voices of education officials, health departments, farmers, Latinos, cities, economic development officials and more who have all spoken out about the need to find a solution that works for all instead of continuing to rely on failed strategies. It’s time we moved on to solutions that science tells us will help.

Below, some of the people that will be impacted by this new plan give their thoughts:

Drinking Water Quality and Availability Will Be Negatively Impacted

“Let us be clear. The detrimental impacts of the Board’s plan will be felt strongly by the children that we serve. . . it is unclear why you have not taken the time to study the financial implications to school districts that would be forced to provide bottled water and portable toilets, or relocate schools entirely, as wells go dry. . . Access to drinking water and water for sanitation is a basic requirement for us to fulfill our mandate to provide quality education to the children of our districts.”

Steven Gomes, Merced County Superintendent of Schools
Tom Changnon, Stanislaus County Superintendent of Schools

“Many communities in the Merced area are already experiencing well production problems and drinking water quality issues . . . Over 800,000 people live in the two counties [Stanislaus and Merced]. Groundwater is the primary source of drinking water for the majority of the local population. The plan sorely understates the devastation this recommendation will cause. As an Interim Director of Environmental Health, I am required to ensure that safe, adequate, and dependable water supplies are available for domestic use.”

Vicki Jones, Interim Director of Environmental Health
Merced County Department of Public Health

Jobs and the Economy Will Suffer

“Over 55% of the residents of Stanislaus County are members of minority communities, with a majority of those residents being Latinos. As you know, our economy is largely driven by the agricultural sector, of which Latino workers play a vital role. Our unemployment rates in Stanislaus County are already consistently higher than the state and national averages. There is no doubt that your plan will have devastating economic consequences to an already disadvantaged region.”

Maggie Mejia, President
Latino Community Roundtable

“I am all for protecting the environment to the best of our ability, but not at the expense of our farmers, businesses and citizens. . . When farmers are forced to fallow more land, our food prices go up and the poor in our communities suffer the greatest. This proposal will raise the cost of water and electricity, as well.”

Pamela LaChapell

“As the Director of Environmental Resources for the County, I am responsible for the administration and oversight of over 200 public water systems, approximately 2,000 retail food facilities and countless other businesses. This would be devastating to the local economy.”

Jami Aggers, Director of Environmental Resources
Stanislaus County

“We grew up in Stanislaus County and our parents, grandparents, and great grandparents were all farmers. . . We also are grateful that our children were raised here and their children will be raised here . . .Without water there will be many of us who will not be able to farm and those that work the fields and canneries during the harvest will be unemployed and unable to feed their families, buy clothing and supplies in our local stores. Our electricity costs will increase and our ground water will be depleted . . . we implore you to reconsider.”

George and Annemarie Espinola

“Food production is a multi-billion dollar industry in our county and adds tremendous value to the State of California. . . Tens of thousands of people are dependent on jobs in agriculture, food processing, and its related industries. Our businesses pay millions of dollars in taxes each year to sustain our state government . . . We ask that you please consider our needs in the Central Valley with others’ needs and wants.”

David White, Chief Executive Officer
Stanislaus Business Alliance

And yet the Board wants to keep doing more of the same even though it has been proven ineffective  

“Simply flushing water down the river in the spring and fall does not work – a fact supported by more than two decades of proven science.”

Robbie Lake
French Camp

“I’ve lived on the Stanislaus for 40 years. Salmon are declining and the striped bass are increasing. What the state is doing is creating the opposite effect of what it says it wants.”

Jeff McPhee

“[The proposed regulation] is yet another demonstration of the complete disregard you hold for the people you are supposed to be serving. . . I encourage you to reduce your personal water use by 35% and pour that extra water into the street and watch it flow away. That is what you would be doing to the people you serve.”

Roxanne Garbez

People Are Asking for Common Sense, Balance and an End to Tactics That Just Make a Bad Situation Worse

“We need a common sense approach to how this water is used. . . In your efforts to help, you are creating a bigger problem than we had before.”

Nancy Petersen

“We have worked hard to be good citizens and lower our water usage in the face of this drought. In fact, the Central Valley has led the state in water conservation efforts . . . We implore you to send staff to meet with us and come up with a common sense approach to this situation.”

David White, Chief Executive Officer
Stanislaus Business Alliance

“Why add water to the ocean? Does it need more?”

Suzy Fivecoat

“It is time we manage our water resource in a way that is fair to everyone and strikes a balance between water supply and the environment.”

Roseanna Swanberg

Statement on the upcoming release of proposed flow standards for tributaries to the San Joaquin River

Flowing River

Statement by California Farm Water Coalition Executive Director Mike Wade on the upcoming release of proposed flow standards for tributaries to the San Joaquin River

California officials are on the verge of releasing new water regulations

waterboards_logo_high_resthat would cause significant harm to California residents without quantifying any specific environmental benefits.

The State Water Resources Control Board is expected to release its Water Quality Control Plan on Thursday, September 15 that would set new requirements for water flowing in tributaries to the San Joaquin River.

The expected result is the direct loss of 350,000 acre-feet of water that is currently used to grow food on 100,000 acres of prime farmland. It is enough water to serve the domestic needs of 2 million Californians or produce almost 5.8 billion salads.

“If implemented, the State Water Board’s rule will have a devastating impact on drinking water, sanitation needs, food production, the economy and jobs for people stretching from the Northern San Joaquin Valley throughout the Bay Area. That’s why this regulation is opposed by schools, health departments, farmers, Latinos, cities, economic development officials and more,” said Mike Wade, executive director of the California Farm Water Coalition.

“It is unbelievable that our government would propose regulations that their own staff say will put farms out of business, reduce water supplies and have negative impacts on groundwater. Yet they can’t tell us what, if anything, this will do to protect the environment.

“The reason they cannot demonstrate benefit is because science clearly shows that decades of releasing water to the ocean has failed to halt the decline of Chinook salmon and Delta smelt. It is time to stop relying on failed strategies and move on to solutions that science tells us will help.”

Farmers helping fish

Figure2b_RedwoodCreek-1There has been considerable conflict lately between water users and fishery managers over the operation of the Sacramento-San Joaquin Delta. Biological opinions dating back to 2008 and 2009 have wreaked havoc on water supplies for farms, homes and businesses in the San Joaquin Valley and Southern California. Between December 1, 2015 and April 4, 2016, 913,000 acre-feet of water that could have been put into storage for use later this summer instead went out to the ocean with no measurable environmental benefits. That represents almost 300 billion gallons, or enough water to meet the domestic needs of 5.3 million people for a full year.

That’s why it’s refreshing to hear some positive news about partnerships that benefit both people and the environment. Oakdale Irrigation District and South San Joaquin Irrigation District recently approved a plan to sell up to 75,000 acre-feet of water to farmers in the San Joaquin Valley who have been largely cut off from water deliveries because of the salmon and Delta smelt biological opinions. The water sale benefits the environment because the timing of the releases is being coordinated with environmental pulse flows, which helps push salmon down the Stanislaus River to the Pacific Ocean. Hopefully, three years from now, they will have grown and return to spawn in the river. That’s assuming that the baby salmon can avoid the voracious predatory bass lurking in the Delta that some studies indicate consume over 90 percent of the out-migrating baby salmon.

The water sale benefits the environment because the timing of the releases is being coordinated with environmental pulse flows

The benefit of the transfer revenues to both Oakdale and South San Joaquin Districts is a furtherance of their investments in advancing water conservation activities back home. That’s a triple bottom line if there ever was one. The ecosystem benefits through timing of fish flows. San Joaquin Valley farmers benefit because they faced little to no surface water deliveries for the past three years. And the overall efficiency of California’s water supply system benefits through improved water use efficiency and conservation.

Let’s seek more solutions like that.

Many Delta Stressors Impacting Delta Smelt and Delta Health

Delta bass predation

There are far bigger issues affecting the Delta than water exports and Delta bass predationreturning to a time prior to Western development is unrealistic.

To describe the Delta as altered is to say that New York City is populous or California water politics contentious. Since the 19th century when locals began to reclaim the marshlands, dike the rivers, and develop settlements on the rivers- the history of the Delta has long been one of change. California’s largest river delta, the Sacramento – San Joaquin Delta has been forever altered by human habitation. Little remains of the complex estuary network of tidal wetlands, freshwater rivers and recurring saline incursions.

Long gone are the nuanced networks of sloughs and wetlands that once dominated the historic delta. Today’s Delta is a scene dominated by numerous dried islands often sitting 20-30 feet below the water level just beyond the 1100 miles of earthen dikes. Plans exist to restore more than 30,000 acres of riparian and wetland habitat, but to date these plans continue to undergo environmental review.

Beyond the edges of these islands ongoing dredging of channels for deepwater shipping to the inland port cities of Stockton and Sacramento applies greater pressure to the species looking for shallow water habitat.

The Delta today is one of artificially fresh water- held far to the west of pre-project development, flows originating in the state’s network of reservoirs now support in-delta diversions for use by in-delta agriculture, cities as near as Stockton and as far away as San Diego. It is used to grow avocados on small farms near San Diego and organic cantaloupee near Firebaugh, among more than 300 other types of food and fiber that rely on water flowing through the Delta. as well as providing water to more than 25 million Californians.

There are numerous stressors impacting the health of the Delta and the threatened and endangered species living there, including the Delta Smelt. The region’s biosphere has changed dramatically and is now dominated by invasive species that have decimated native fish populations.

The National Marine Fisheries Service has stated that predation by non-native bass on winter-run salmon is a “major stressor,” while widespread invasive Asian clams and other species continue to alter the delta’s complex food network. Industrial chemicals being found in species at the mouth of the bay are also tied to what has been called Pelagic organism decline by researchers studying the health of the Delta.

Regarding the decline of the Delta Smelt, the federal agency responsible for studying and restoring threatened species, the Fish and Wildlife Service, acknowledges that we are unable to determine with certainty which threats or combinations of threats are directly responsible.” Since 1994, Fishery and wildlife regulators have limited their focus to delta exports, though the agency acknowledges that its “existing regulatory mechanisms have not proven adequate to stop the fish’s decline since its listing nearly 20 years ago.

Yet sensational news stories continue, declaring water exports culpable- “With Just Six Delta Smelt Left, Controversial California Fish Species Faces Impending Extinction” and “Threatened Smelt Touches Off Battles in California’s Endless Water Wars” but scientists who study the complex Delta ecosystem suggest that this claim is likely overly simplistic. Researchers discussing the issue with the Wall Street Journal noted that “Other studies have noted that the biggest driver of species abundance in the delta is precipitation, which may explain why the smelt population has plummeted over the past four years of drought after rebounding in 2011—a wet year.”


Suggested changes to the Delta export facilities, intended to reduce possible impacts to threatened and endangered species while restoring reliability to water supplies remain under review, and could allow the Delta to return to a more natural condition, while restoring water supply reliability to more than 25 million Californians and millions of acres of the most productive farmland on the planet.