Letter to State Water Board re: Flow Criteria that use Percent of Unimpaired Flow

The proposed use of percent of unimpaired flow is a step toward improving the outlook for fish and other wildlife utilizing the San Joaquin River and its tributaries. Fall-run Chinook salmon are likely to benefit from February-through-June flows that are more natural in timing and variability than current flows. Compared with the existing maze of flow standards for the San Joaquin River and its tributaries, unimpaired flow comes closer to approximating natural flow, and it does so more transparently.

Caveats include: (1) flow is but one of many stressors affecting fish and wildlife; (2) the choice of flow criteria and metrics needs to serve the broader needs of ecosystems as well as individual species; (3) a chosen percentage of unimpaired flow may fall short of the minimum needed by fish and wildlife in some years; and (4) such critical years are likely to become more common as Sierra Nevada snowpacks diminish as a consequence of climate change. This qualified endorsement is based on our reading of the “Technical Report on the Scientific Basis for Alternative San Joaquin River Flow and Southern Delta Salinity Objectives” (State Water Resources Control Board, February 2012).