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San Francisco Baykeeper urges board to reject voluntary agreements in Bay‑Delta plan, cites recent operations harming salmon
Summary
Christy Ralston of San Francisco Baykeeper told the State Water Board that incorporating voluntary agreements into the Bay‑Delta water quality control plan is “untenable,” citing spring 2025 Central Valley Project and Bureau of Reclamation operations that she said exceeded limits in 2024 BiOps and ITPs and caused losses of protected fish.
At the State Water Resources Control Board public forum on June 3, Christy Ralston, representing San Francisco Baykeeper, urged the board to reject voluntary agreements (VAs) as a regulatory pathway for updating the Bay‑Delta water quality control plan.
Ralston told the board that spring 2025 operations by the Central Valley Project (CVP) and the Bureau of Reclamation “made clear that such a path forward is untenable as it relies on the good faith participation of VA signatories, which is uncertain to occur.” She cited three specific concerns she said illustrated the problem: that the CVP and State Water Project exceeded the annual loss limit for hatchery winter‑run Chinook salmon in March and April 2025; that the projects exceeded the three‑year rolling average loss for Central Valley steelhead in early March; and that Reclamation did not implement early VA actions to reduce exports needed to meet a proposed San Joaquin inflow to export ratio. Ralston said those examples show the risk of relying on voluntary compliance and called for “a regulatory pathway with clear, specific, science based, and enforceable provisions.”
Authorities and evidence cited by speaker: Ralston referenced the 2024 NIPS BiOp and the 2024 CISA ITP (as cited in her remarks) and said Reclamation “flouted” and “ignored” measures required by those documents during its spring operations, resulting in fish losses.
Board response: Chair Joaquin Esquivel thanked Ralston for her testimony. The item was part of the public forum; no board action was taken in response to the public comment.
Ending: Ralston asked the board to adopt an updated Bay‑Delta water quality control plan that rejects voluntary agreements and instead employs enforceable, science‑based regulatory provisions to protect the Delta ecosystem and public trust resources.
