Review of SWRCB’s “Working Draft Scientific Basis Report for New and Revised Flow Requirements on the Sacramento River and Tributaries, Eastside Tributaries to the Delta, Delta Outflow, and Interior Delta Operations”

Insightful, informative, well-illustrated, clearly written—these are among our overall impressions of “Working Draft Scientific Basis Report for New and Revised Flow Requirements on the Sacramento River and Tributaries, Eastside Tributaries to the Delta, Delta Outflow, and Interior Delta Operations”. The comments below focus on recommended improvements.

In particular, we recommend clarifying, and further justifying scientifically, the proposed use of percent of “unimpaired flow” as the main basis for establishing an annual environmental water budget. We also suggest presenting a further review of cold-water management, a deeper analysis of non-flow stressors, additional consideration of near-term responses to climate change, and elaboration of how regulations managed adaptively may improve scientific understanding of environmental flows.