After excessive water diversions by the Los Angeles Department of Water & Power (DWP) destroyed more than eight miles of Rush Creek in the Mono Basin, the State Water Board mandated the restoration of the fishery, riparian forests, wildlife habitats, and biodiversity of the creek. Rush Creek restoration should not suffer because DWP has delayed the long-overdue replacement of its malfunctioning aqueduct intake valve.
I am concerned about the Temporary Urgency Change Petition request submitted by DWP that asks the State Water Board for permission to skip delivering the required springtime high flows to Rush Creek that are essential for the damaged creek’s recovery.
DWP’s request neglects the restoration of Rush Creek and essentially asks for a free pass. DWP offers no measures that attempt to achieve the required flows, no mitigations for impacts, no alternative operations plans, no collaboration with key parties, and no contingency plans.
In fact, DWP is actively impeding restoration by simultaneously planning to maximize water exports from the Mono Basin this year. This will lower Grant Lake Reservoir, just like DWP did last year by exporting in excess of the Los Angeles mayor’s 4,500 acre-foot voluntary commitment. And a low reservoir reduces the chance of a beneficial reservoir spill that serves as mitigation by providing restoration flows that can no longer be delivered through DWP’s malfunctioning aqueduct valve.
This TUCP is the second of what appears will be many requests for flow waivers. DWP has been aware of its deteriorating aqueduct infrastructure for a decade, and DWP studies say it will take at least another decade to complete repairs. I call on the State Water Board to make certain that Rush Creek is not impacted by DWP’s lengthy repair project and to mitigate the impacts caused by DWP’s delay in constructing the outlet at Grant Lake Dam.
DWP proposes that the Board waive its own stream restoration requirements year after year with absolutely no mitigation or conditions. Instead, the Board should address the limitations of DWP’s failing infrastructure by ordering requirements designed to continue the restoration of Rush Creek until DWP’s repair work is successfully completed.
At a minimum, the State Water Board’s requirements should include interim operating rules for Grant Lake Reservoir that promote beneficial springtime reservoir spill, alternative water delivery systems for Rush Creek, frequent meetings of the involved parties to ensure collaboration, impact mitigations, and contingency plans in case of further valve failure.
Thank you for the opportunity to comment. The State Water Board’s decades-long restoration program should not have to suffer as a result of DWP running its infrastructure to the point of failure. A healthy Rush Creek is valuable and critical asset for fish, wildlife, and all Californians.
Sincerely,
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