As Turlock Irrigation District analyzes the State Water Resources Control Board’s water grab proposal aimed at this region, we’re learning more about the State Water Board’s so-called product. And the more we read, the worse it gets.

Thanks to the community advocacy surrounding this proposal, also known as the Phase 1 Revised Substitute Environmental Document (SED) of the Bay-Delta Water Quality Control Plan, you have likely already heard about the impacts of such a dramatic increase in instream flows to the Tuolumne River. The proposal is so much worse than just requiring anywhere from 30 to 50 percent more water to flow every year from Don Pedro Reservoir into the Tuolumne River.

First, the State Water Board’s staff proposal includes a starting point of a 40 percent increase in unimpaired flows on the Tuolumne, Merced and Stanislaus rivers every year from February through June. One analysis we performed indicates that if the SED were in place during the 1990-2015 period, TID would have been able to deliver a full amount of available water in only five out of 26 years. And during both the 2014 and 2015 irrigation seasons under the SED, our farmers would have received zero water.

Second, on top of devastating our community by demanding 40 percent of unimpaired flows, the state is proposing to take control of Don Pedro Reservoir by requiring an annual carryover storage requirement. Come each September, before the irrigation season wraps, approximately 50 percent of Don Pedro’s available water would be required to be held back. Don Pedro was built by our community to allow our region to survive a prolonged drought like the current one, but the SED removes our ability to do so in the future.

Third, the SED is ill-conceived, has countless flaws, masks major impacts with averages, makes broadstroke assumptions and relies upon out-of-date science; all for its stated purpose of providing “reasonable protection of fish and wildlife beneficial uses in the (Lower San Joaquin River) Watershed, and its three eastside salmon-bearing tributaries”. However, the SED’s own analysis of the production of fall-run Chinook salmon shows an average increase of 1,103 fish annually. For such a small tangible increase in fish, we think that’s an amount of water that is neither reasonable nor beneficial.

Fourth, science conducted by TID and MID on the Tuolumne River is conveniently absent from the SED. The Districts have spent more than $25 million the past few years to develop the most focused, most recent, most collaborative science on the river. The results of these studies tell a different story and provide different solutions than the narrative weaved together by the State Water Board in the SED.

Fifth, there is a host of other issues we’ve encountered in the SED, like how it is void of any consecutive dry-year relief for the irrigation districts during droughts, or how putting the proposed amounts of water in the rivers in February or June may be harmful for fish. Let’s not forget most salmon, as high as 98 percent in some years, are getting eaten by non-native predatory species like bass before they exit the Tuolumne.

Last, the SED dramatically harms the nearly two-year effort by our local water agencies who are diligently working to achieve the state-mandated groundwater sustainability goals outlined in the Sustainable Groundwater Management Act (SGMA). If implemented, the SED will be the direct cause of groundwater reduction in our region, making it nearly impossible to achieve groundwater sustainability.

We’re asking our community to attend either the Dec. 19 public hearing in Merced at Merced Theatre or the Dec. 20 public hearing at Modesto Centre Plaza (both start at 9 a.m.) and share with the State Water Board how this misguided proposal will impact your businesses, your communities and your families.

We plan to tell the state there is a better way to balance a healthy economy and a healthy ecosystem, because the way it sits right now, no one is buying the product that the State Water Board is selling.

— Casey Hashimoto is General Manager of the Turlock Irrigation District.