MODESTO, Calif. — The Almond Alliance of California, in conjunction with the Almond Board of California, recently submitted formal comments opposing the State Water Board’s unimpaired flows proposal. Opposing comments detailed that a state proposal recommending a range between 30 and 50 percent of unimpaired water flow, starting at 40 percent, for the San Joaquin River and tributaries is “misguided” and the supporting documentation is “deficient” across a broad range of issues.
As part of its update to the Bay-Delta Water Quality Control Plan, the State Water Resources Control Board (SWRCB) issued a staff proposal last fall that would require water users to leave significantly more water in the San Joaquin River and its tributaries from Feb. 1 to June 30 each year in an effort to provide fish and wildlife benefits.
The California almond industry offered formal written comments on the proposed Phase 1 amendments to the Bay-Delta Water Quality Control Plan and the accompanying Substitute Environmental Document (SED).
Noting that fisheries, like agriculture, need many ingredients to be successful, the letter calls on the water board to support policies that “support regional agriculture and restore healthy native fish populations. We support efforts to create a healthy balance based on sound science and best available technologies maximizing benefits from each drop of water… The SED, as drafted, does not balance benefits and impacts, as the impacts have been grossly understated.”
The letter was particularly critical of the proposal’s economic analysis: “The amount of errors, omissions, and unsupported assumptions, including grossly underestimated acreage, is astounding. We have identified that under one scenario there is a potential impact to almonds alone of over $37M — over half of the total estimated agricultural impact of $64M. Additionally, the analysis incorrectly assumes the farmers’ ability to transfer reduced water supplies to higher value crops such as almonds which results in significant underestimation of economic impacts. The Water Board needs to work with water districts and the local counties to identify the true economic impacts of this project.”
The comments pointed out the economic benefits of the almond industry and the potential economic consequences that could result from the water diversions. The farm-gate value of California almonds was $5.3 billion in the 2015-16 crop year. Through farming, manufacturing and associated industries, the California almond industry creates over 104,000 jobs throughout the state with 97,000 jobs in the Central Valley, an otherwise economically depressed region.
The letter said both the Almond Alliance and the Almond Board were ready to work with the water board on improving the project and analysis, “including development of negotiated agreements, to ensure that farming’s long-term prospects and sustainability are enhanced, alongside the increased sustainability of the region’s fisheries.”
Here are key highlights from the formal comment letter signed by Almond Alliance President Kelly Covello and Gabriele Ludwig, consultant to the Almond Alliance.
Project balancing. Balancing requires developing accurate estimates of benefits for and impacts to all beneficial uses, and selection of the least damaging alternative necessary to achieve fishery goals, maximizing non-flow, adaptive management methods and mitigating impacts to farm water supply. The SED as drafted does not balance benefits and impacts as the impacts have been grossly understated.
Stakeholder Engagement and Process. The Water Board needs to engage and ensure the SED is vetted with irrigation districts and agricultural stakeholders, update the SED with missing germane fish science, and correct the SEVERE underestimation of water supply and agronomic impacts. Negotiated agreements need to address this collaborative shortcoming, while accounting for the complex and simultaneous state and federal policy and regulatory processes.
SGMA policy conflicts. It is inappropriate to use a “speculative” analysis to assess the impacts of project implementation without combining it with recent groundwater legislation. Doing so creates a major policy conflict for farmers and system operators, and the livelihoods of Central Valley farmers and their employees cannot be destroyed based on speculation. Using a “speculative” analysis that leaves out SGMA also limits conjunctive management, groundwater recharge, and storage opportunities. It is the responsibility of this Water Board to take a holistic and statewide approach to agricultural water policy and planning; growers must comply with all regulations, and it is a complete injustice for the Water Board and other water agencies to operate in silos.
SWAP economic analysis. The amount of errors, omissions, and unsupported assumptions, including grossly underestimated acreage, is astounding. We have identified that under one scenario there is a potential impact to almonds alone of over $37M — over half of the total estimated agricultural impact of $64M. Additionally, the analysis incorrectly assumes the farmers’ ability to transfer reduced water supplies to higher value crops such as almonds which results in significant underestimation of economic impacts. The Water Board needs to work with water districts and the local counties to identify the true economic impacts of this project.
Click Here for the full comment document.
The Almond Alliance of California is a trade association representing the interests of the California Almond industry including almond growers, hullers/shellers, and processors. For more information, visit almondalliance.org
—Almond Alliance of California
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