New SOUTH DELTA WATERAGENCY · 2017. 5. 18. · According to plant and soil science, plant health...

SOUTH DELTA WATERAGENCY 4255 PACIFIC A VENUE SUITE 2 STOCKTGgtNCALIFORNIA 95207

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Jeny Robinson Chairman Robert K Ferguson Vice-Chairman Counsel amp Manager Natalino Bacchetti John Herrick Jack Alvarez Mary Hildebrand

April 142017

Via email jamesbrownellwaterboardscagov

Mr James Brownell Central Valley Regional Water Quality Control Board 11020 Sun Center Drive 200 Rancho Cordova CA 95670-6114

Re Amendments to the San Joaquin River Basin Plan to Adopt Salinity Water Quality middotobjectives for the Lower San Joaguin River

Dear Mr Brownell

The South Delta Water Agency objects to the draft Salinity Objectives being proposed for adoption on the Lower San Joaquin River as unsupported by the technical work underlying the basis for the Objectives The proposed Salinity Objectives are not based on any technical investigations of leaching occurring in the subject area but are based on assumed and agreed to data which may or may not be correct The analysis done by staff and the Lower San Joaquin River Committee continue the faulty practices done by the State Water Resources Control Board in support of its efforts to relax southern Delta salinity standards in order to avoid the need to enforce water quality objectives

SOWA has on numerous occasions presented the State Board with facts which not only disputes their salt and leaching analysis but clearly shows such analysis is simply not scientifically sound That analysis is based on Dr Glenn Hoffmans previous work which is now known to be incorrect and unreliable as will be explained below To be clear this is not a disagreement between approaches or modeling or opinion Dr Hoffmans work done for the southern Delta salinity objectives is just plain wrong By employing this incorrect approach and having failed to do any actual testing of leaching in the subject area the staffand LSJR Committee have produced recommended salinity objectives that lack any scientific support

By way of introduction the issue is of course the protection ofagricultural beneficial uses

along a portion ofthe San Joaquin River a protection now nearly 20 years past due Generally salts (and boron) are the constituents in River water that can most affect agricultural plant growth and crop production Even though other constituents can have effects on crops the control of the salts will for the most part provide the necessary protection for agricultural dependant on River water supply

According to plant and soil science plant health and crop production are a function of the soil salinity Measuring or maintaining short term soil salinity is practically impossible and so the yearly ( or seasonal) soil salinity is used to estimate whether or not a particular crop is being affected Thus each crop has a predeterminedcalculated soil salinity threshold Once the soil salinity rises toabove that threshold damage to the plant and also to crop production increases Protection therefore is maintained by keeping the soil salinity below the threshold

Salts affect plant water uptake by interfering with the osmotic process by which plants take water into their rootsmiddot To maintain acceptable levels of salt in the soil enough water of a certain quality must pass through the soil in order to move salts out of the plant root zone This process is called leaching and the leaching fraction is the number given to the percentage of water passing through the soil Thus one can calculate the leaching fraction needed in order to pass the delivered salt ( delivered in the applied irrigation water) through the soil so salt does not build up and one can calculate the actual amount of leaching fraction occurring in any particular field

The ability ofwater to pass through a soil is dependent on a number offactors especially middotofcourse the permeabilityporosity of the soil Different soils have different permeabilities so leaching occurs at different rates in different places For example a sandy soil may pass water more easily than does a clay soil The problem is not simply solved applying more water to push the salts through the soil This is because some roots are susceptible to rot and disease if they are wet too long In other cases the management practices preclude longer or continuous irrigations Alfalfa fields must dry out in between some irrigations in order for mowing raking and baling to be done This means that the grower cannot simply irrigate longer in order to accomplish adequate leaching

With this background I will now explain the fundamental faults with the Hoffman approach The following is taken from the SOWA comments to the SWRCBs Draft SED examiningjustifying proposed relaxation of the southern Delta salinity standards The reader should not assume these duplicated comments are not germane to the subject issue as the comments show that absent reliable data the Hoffman approach is simply guessing and not a scientific examination

HOFFMAN REPORT

The basis for the SWRCB s proposed changes to the southern Delta water quality objectives is the January 2010 report by Dr Glenn Hoffman Salt Tolerances ofCrops in the Southern Sacramento-San Joaquin Delta (Hoffman Report) As related in the Hoffman Report impacts to crops are estimated to occur when the EC ofthe soil reaches a thresholdor any particular crop In additiorl individual applications ofhigh saline water can also adversely affect plants and crops even when the soil EC threshold is not reached The Hoffman Report uses no current data relies on no actual sampling and testing ofsoils and contains no actual

data on existing conditions in the southern Delta Because ofthis both Dr Hoffman and the single peer reviewer ofDr Hoffmans work state that additional sampling and testing were desirable

There are two ways to determine ifsalts are building up in the root zone ofagricultural crops One is to actually measuremiddotthe salts in the soil and the other is to calculate the soil salt and how it might be changing The calculation method attempts to determine the leaching fraction ofa particular area The leaching fraction is the amount ofadditional applied water (ofa certain quality) above thf] amount neededused by the plant and which passes through (out of) the root zone Leaching fractions are normally expressed as a percentage This amount or percentage of extra water is the means by which salts move out ofthe root zone

In order to calculate leaching fractions for the southern Delta Dr Hoffman used a specified waler quality for the applied water and 1986 1987 and 1989 data from the sampling of tile drains (see Table 3 10 ofHoffman Report) In nonscientific language Dr Hoffman used applied water EC as the salt in to the soil and tile drainage EC as the salt out ofthe soil 1

Dr Hoffman assumed the applied water quality was 0 7 dSm EC (to be consistent herein I will convert from the dSm scale to the mSm scale in this instance converting 0 7 to 700) There is no basis for such an assumption Data from DWR indicates that the EC at the three interior southern Delta compliance locations is regularly above the 700 EC levels in summer months (see for example attached DWR Water Quality Data) Dr Hoffman made no attempt to determine what the range ofECs were in anyparticular year or in any year types Neither did Dr Hoffman or SWRCB staffseek data from individual farmers who regularly take EC measurements Attached hereto is a declaration I prepared and signed giving one example of

- such local testing In June of2015 l sampled the supply water from the southeastern end ofTom Paine slough as 2200 EC Thus when Dr Hoffman assumed the salt in as being 700 EC he was not using actual or accurate data he was simply guessing

For the salt out inputs Dr Hoffman used the tile drain data referenced above However to be useful the tile drain water (which was originally sampled and the EC thereof measured) would have to be the excess applied water which passed through the root zone which transported the applied salts through the soil Instead those tile drains (described in pages 51shy53 ofthe Hoffman Report) contain mostly shallow ground water and not excess applied water The ground water in that area is very saline (see attached Statement ofJack Alvarez) Thus Dr Hoffman s data for how much salt is being passed through the soilprofile is simply not that

Therefore Dr Hoffman used the incorrect salt in data (understating applied salt) and incorrect salt out data (overstating salts leached from the soil) The results therefore may indeed be calculation outputs or modeling results but they bear no relationship to what wasis happening to salt levelsmiddot inmiddotsouthern Delta agricultural soils Not only can one not calculate an accurate leaching fraction by using incorrect and irrelevant data but one also cannot thereafter estimate what quality ofwater is necessary Jo protect agricultural beneficial uses Once the

Dr Hoffman also references some other drainage and tile drainage data but again never confirms if the water in that drainage was from poor quality ground water excess applied water or

_ some combination thereof

initial incorrect data was used Dr Hoffmans entire effort and certainly his results are merely some hypothetical math exercise and useless in evaluating southern Delta salinity issues

The only effort made to address this fundamental fault in the work was when Dr Hoffman added another lower leachingfraction (15) to his work and still concluded that the objectives could be relaxed Ofcourse such a correction does not cure the underlying problem unless this new leachingfraction he later inserted was indeed an accurate representation ofleaching fractions for southern Delta soils As one might assume ii was not as will be explained below

The Hoffman Report suffers from other inaccuracies and misconceptions which also preclude its use to justify a relaxation ofwater quality standards Water and the dissolved salts in it must pass through the soil in order middot10 leach salts from the soil (or prevent their buildup) However aspreviouslypresented to SWRCB staffand Dr Hoffman the permeabilitiespercolation rates ofsouthern Delta soils inhibit ifnot actually prevent the water from movingfast enough to accomplish any leaching (see attached Water Quality Considerations for the South Delta Water Agency Hoffman Prichard and Meye1j Also attached hereto is the Outline ofTestimony ofAlexander Hildebrand on South Delta Agriculture by Alex Hildebrand explaining this problem with many southern Delta soils Mr Hildebrand relates how slow percolation rates can prevent a farmer from applying the necessary additional water lo leach the soil because the field must be allowed to dry out before the next irrigation is necessary Because ofthis the farmer ends up adding more and more salt over the season and the crop suffers

Though perhaps not a controllingact Dr Hoffman sfamiliarity with the underlying issues associated with farming perhaps helps explain why his work is not reliable At a

middotmiddot workshop early in this process Mr Hildebrand explained publically to Dr Hoffman that he was not considering real-life problems in his analysis Mr Hildebrand explained how the management practices for alfalfa included mowing raking and baling upwards of8 times a season and how this regular vehicle traffic over the fields further compact the soils and exacerbates the low permeability problems Dr Hoffmans now semi-infamous reply was that he could not help it iffarmers had bad management practices Ofcourse such a comment lays bare the technical shortcomings ofthe process and also how difficult ii is to get experts to change their mind even in light ofirrefutable evidence Alfalfa cannot be farmed without vehicle trafficfor mowing raking and baling

This example also recommends a change to the entire process Since the first agricultural objectives were developed for the Delta the SWRCB and most interested parties have focused on measuring impacts to salt-sensitive crops Thus the current SED as well as the manyprior efforts all look to how applied water quality might affect beans a salt sensitive crop This perhaps makes sense in the lab where plant scientists pour water into containers of sand to see how much water passes through the soil and the degree to which salt may

accumulate in the soil However the real world is something different atogether

The degree to which any plant may be sensitive to salt may not be the most important concern in developing a water quality objective Ifthe soils do not allow adequate leaching then the salt delivered via the applied water never gels fully flushed out ofthe root zone and eventually that plants particular threshold is reached and the crop suffers Ofcourse for any particular crop the time it takes to reach the threshold may differ but the issue is not so much

how sensitive the plant is its whether or not salts are being flushed out ofthe soil Dr Hoffman sfundamental error was thinking that he could calculate the leachingfractions ofthe soil and that his calculations need nor be ground-truthed One cannot know ifa soil is allowing enough water to pass through to allow leaching without measuring what is actually going on in that particular area Modeling leaching is at best a guess and in this case a very bad one

Lastly with regard to the Hoffman Report it must be noted that in his attempts to use tile drain data Dr Hoffman failed to investigate (or understand) the many differences in the southern Delta The southern Delta has land that is 20 feet above sea level and land that is 5 feet below sea level Some ofthe lands get water from near Vernais which is generally kept at or below the objective some get water from interior areas that are stagnant and higher in salinity (than the water at Vernais) some get export quality water either from the cross Delta flow or directly from the CVP s Delta Mendota Canal and everything in between Many areas have shallow ground water ofverypoor quality and the plants roots are in contact with that poor quality water In some areas the tides directly affect ground water levels and thus twice daily raise the poor quality ground water up and down in and out ofthe root zone This inhibits ifnot prevents salts from permanently passing through the root zone A myriad ofdifferences determines the ability or success at leaching

Though some ofthese peculiarities were mentioned by Dr Hoffman none were actually taken into account in his work For example the notion that tile drains in the southeastern portion ofthe area are typical ofdrainage in other southern Delta areas is false on its face Those drains are in soils and area that have little in common with other areas Thus even ifthe tile drain data were accurate representations ofwater that only passed through the soil (and it is irrefutably it was not) it would still not be reflective of drainage from other areas or indicate how much salts passes through other root zones In this same vein Dr Hoffman did not determine ifthe supply water for the lands served by the tile drains was from the Delta channels orfrom the DMC Such lack ofground-truthing cannot support changes to water quality objectives

As we see the Hoffman Report simply cannot support changes to water quality objectives The only evidence bearing on the issue ofwhat quality ofwater is necessary to reasonably protect agricultural beneficial uses was in fact produced by the SDWA

LEINFELDER-MILES REPORT

In response to Dr Hoffmans inaccurate Report and to the SWRCB staffs unwillingness to recognize the deficiencies therein SDWA in conjunction with grantfimdsfrom UC Davis retained Michele Leinelder Miles_to conduct a study The study is entitled Leaching Fractions Achieved in South Delta Soils Under Alfalfa Culture Project Report Updated December 2016 and is attached hereto Ms Leinfelder-Miles is the Delta Resource Management Advisor with the University ofCalifornia Cooperative Extension based in San Joaquin County For the investigation seven locations were selected throughout the southern Delta lo get a sampling of different soil types and different water qualities The basic design ofthe study was to sample and measure the soil salinity in the root zone at the beginning ofthe irrigation season sample the applied water used for each irrigation and measure its salinity and then sample and measure the soil salinity at the end ofthe season In this manner the study would determine the amounts

ofsalts applied and how much ofthose did or did not remain in the root zone (were or were not leached out)

The data was collected in the years 2013 and 2014 and the results are in the attached study and were presented to the SWRCB orally at its December 2016 workshopmeeting held in Stockton California The oral and written materials at that workshopmeeting are incorporated into these comments In general Ms Leinfelder-Miles study found that ofthe seven locations five never achieved a leaching fraction greater than 8 and ofthe 14 results (seven sites over two years) halfhad leaching fractions at or Jess than 5 with results of3 and 2 in certain cases Recall that Dr Hoffman calculated leachingfractionsfor the southern Delta at 20 and above and then later added a 15 leaching fraction analysis after the initial criticisms to his work

The conclusions reached by Ms Leinelder-Miles were (i) salinity in the area is a problem because ofthe low permeability ofthe local soils poor quality applied water and shallow groundwater (ii) the data indicates that leaching fractions being achieved are very low such that salts are building up in the soils potentially harming crops and (iii) local conditions and best management practices constrain farmers ability to leach salts

Thus one the one hand the SWRCB has before it calculated leaching fractions by Dr Hoffman which were arrived at using incorrect and irrelevant data On the other hand the SWRCB has Ms Leinelder-Miles study which actually determined leaching fractions based on specific current data That data shows very low leaching fractions and a buildup ofsalts in the soil As stated above the question before the SWRCB does not hinge on a choice between two sets ofdata or two opposing opinions The only accurate reasonable and reliable data that exists does not support a relaxation ofthe waler quality objectives To the contrary it suggests current standards are insufficient That conclusion is perhaps premature in that we do not generally know ifthe current objectives are protective because DWR and USBR do not regularly meet the standards and the SWRCB does not enforce the standards Regardless there is no data supporting a relaxation ofthe water quality objectives for agricultural beneficial uses in the southern Delta

It becomes clear from the above that although the Hoffman approach might be useful as an overview ofhow to calculate leaching fractions in practice is does not predict actual leaching and cannot therefore be used as the basis for determining a salinity standard Dr Hoffman used faulty data because he did not conduct any studies nor find any studies showing what leaching fractions were occurring or what soil salinities were resulting from the application of the available water supply When confronted with the inaccuracies of his results Dr Hoffman simply added a new lower leaching fraction instead of taking note that the actual leaching fractions being achieved were sometimes I1 0th what he had calculated The real data from actual testing showed that salts were collecting in the soils The calculated data indicated no such problem

Thus we arrive at the proposed Water Quality Objectives being considered by the Regional Board The staff and LSJR Committee conducted no sampling no testing and no field analysis at all There is no data on existing soil salinities There is no data on actual leaching fractions being achieved There is no data on whether current conditions are increasing soil salinity There is no data on how the proposed objective will affect soil salinity There is no data

on whether current conditions are harming agriculture The authorsproponents simply decided what inputs to use and then decided which leaching fraction to use That may be fine as a thought experiment but is does not suffice as scientific analysis

When the actual data was used to calculate southern Delta leaching fractions it was revealed that the outputs from the Hoffinan work had no relation to reality Given this track record of the approach there is no basis for concluding its application in this instance is correct or reliable It is worth noting that the LSJR Committe process has been ongoing for a number of years and that the two year southern Delta study conducted by Ms Leinfelder-Miles cost somewhere around $40000 in total During the development ofthe subject Water Quality Objectives a similar study could have been conducted with virtually no impact on the overall fundingexpenses of both the CV-SAL TS and LSJR Committee The reliance on the Hoffinan approach instead ofusing actual scientific studies should give the Regional Board pause for thought In todays environment it all too easy to assume that a calculation or model will give reliable results

The above indicates that there is no real technical support for the proposed salinity objectives However the proposed Basin Plan AmendmentAgricultural Water Quality Objectives suffer a number ofother fatal flaws

First the analysis deals mainly ifnot almost exclusively with almonds and other crops which constitute the majority ofcrops currently farmed in the subject area By limiting the analysis to these crops and ignoring crops with smaller acreage the proposal pre-determines agricultural choices During the development ofthe proposed changes to the southern Delta salinity standards it was noted that beans a salt sensitive crop were no longer farmed as extensively as in the past Thus it was argued that since it covered much less acreage the standard need not be protective of that smaller crop This is ofcourse contrary to logic Crop choices are a reflection ofa number of things especially changing market conditions What is only minimally farmed now may change ifprices increases for that crop or decrease for some other crop By not protecting beans or some other crop the Regional Board is in fact precluding farmers from begin able raise that crop given the poor water quality allowed by the new objectives

Staffshould be aware of the Delta Protection Commissions Economic Sustainability report issued a few years back In that report the DPC found that there was a direct relationship in the Delta between increasing applied water salinity and changes to less salt sensitive crops Thus not only does a lax salinity standard prevent a farmer from changing to some crops it also forces him to move away from some crops

Second it is unclear where the notion that the Objective should protectallow 95 crop yields instead of 100 It is not clear what federal or state water quality laws are aimed at partial and not full protection It appears the staff is hanging its collective hat on the notion that all one needs is reasonable protection under Porter-Cologne Ignoring the fact that federal law has no such caveat the word reasonable in that phrase refers to the ability to provide the needed level ofwater quality It does not create an authorization to protect only a part of the beneficial use

Along this same line the Draft Basin Plan Amendment makes no analysis of how that 5 decrease in a crop translates into an effect on the farmer If the profit margin for a farmer is

small andor it is only when he produces a certain amount per acre that he makes a profit the automatic loss of5 ofhis crop each year might be a controlling factor is his ability to survive I find no analysis in the supporting documents to justify the decision to only prevent most of the harm to the beneficial use Further when the objective relaxes even more during dry times the Regional Board is then forcing an even larger decrease in the farmers economic viability

This of course makes no sense If the purpose ofan objective is to protect a specified beneficial use but the objective predetermines a significant harm to the use then the objective is not protective It must be noted that the notion that any farmer would think that a water quality of 1550 EC or 2470 EC is acceptable is bordering on the ludicrous One wonders what CVP contractors receiving DMC water would say if their supply was allowed to be this poor

Which brings us to another shortcoming of the proposed Objectives The proposal is that the 1550 EC will relax to 2470 EC (assuming EC meters can reliably be that accurate) There is no legal authority or plant science support for allowing a one-and-a-half times increase in salinity because of the water year type The soil salinity thresholds for each crop do not suddenly change when less precipitation occurs The relaxation to the grossly unsupportable 2479 EC limit simply means that the beneficial use will not be protected during dry times Worse still it appears that a declared drought emergency will trigger the relaxation We saw in the recent past that the Governor of California declared a drought emergency even when there was no drought but rather based upon Californias long term water crisis Thus by the whim ofone person agricultural diverters suddenly have no protection

Fourth the supporting documents appear to show that full protection would be provided by an Objective of 1200 EC It is not clear why full protection is somehow unreasonable but it is clear that the justification for this choice is a result ofUSBRCVP contractor input The parties who pollute the River with salts have apparently decided that full protection is too much of a burden and so a lesser protection is all that will be condoned

It is important to remember that the Rivers salt problem is a direct result of the CVPs import of upwards of I million tons ofsalt to the valley each year much ofwhich drains into the River via surface drainage and subsurface accretions The starting point for considering a water quality objective should be to first force the party or parties that created a problem to fully mitigate their impacts Thereafter ifsome better quality is required then limitations or

affirmative actions may be required of others Until the USBR mitigates its impacts there should be no Basin Plan Amendment Without the foreign CVP salts in the River ( or the CVP caused decreases in River flows) all beneficial uses might be protected

Lastly it appears from the record and statements from LSJR Committee personnel that the relaxation to 2470 EC was the result of some sort of meeting of the minds Ofcourse that is not what constitutes sound Basin Plan policy but it also appears that the decision was based on the question would you rather have bad water quality or no water Such a choice is not part ofsound Basin Plan development It may or may not be the obligation of any party to insure water is in the River to protect beneficial uses A party may or may not be legally entitled to divert the water in the River under varying circumstances However the protection of beneficial uses is not a function ofUSBR or CVP contractor willingness to make releases into the River The responsible parties should mitigate their impacts not begrudgingly agree to partial mitigate while threatening those who are each year adversely impacted by the ever-present CVP salt

SDWA urges the Regional Board to not adopt the proposed Basin Plan AmendmentAgricultural Water Quality Objectives currently being considered Instead the Regional Board should immediately authorize a leaching study similar to the one done in the south Delta and from that result determine what is necessary to protect agricultural beneficial uses along the River During that time the Regional Board in conjunction with the SWRCB should develop the appropriate enforcement action to require the USBR to mitigate its adverse effects to the River The Regional Board is reminded that PL 361-108 (HR 2828) requires the USBR to develop and implement a program to meet all of its water quality obligations in a manner that decreases its use ofNew Mel ones The regulators ofwater quality should not allow the USBR to avoid its federally mandated obligations

Please feel free to contact me ifyou have any questions

Very truly yours

JOHN HERRICK

shy

+ bull

Leaching Fractions Achieved in South Delta Soils under

Alfalfa Culture

Michelle Leinfelder‐Miles Delta Crops Resource Management Advisor

UC Cooperative Extension San Joaquin County

State Water Resources Control Board Hearing

Stockton CA

December 16 2016

Why is salinity an important consideration in (Delta) agriculture Salt problems occur on approximately one‐third of

all irrigated land in the world bull In general bull In the Delta

bull Parent material bull Many soils have low weathers to form salts permeability and are

difficult to leach bull Some soil amendments may contain salt bull Surface water used for

bull Salts are carried in irrigation and quality

irrigation water may be degraded when it reaches the Delta bull Influenced by shallow

saline groundwater bull Below sea level

Effects of Salinity on Plant Growth

bull Osmotic stress (most common means by which salt impairs plant growth)

bull Specific ion toxicities bull Degraded soil conditions that limit plant water availability

Leaching is the Primary Management Strategy for Salinity

bull Leaching must be practiced when soil salinity has the potential to impact yield

bull Leaching occurs when water is applied in excess of soil moisture depletion due to evapotranspiration (ET)

bull Leaching may occur during the rainy season or whenever an irrigation event occurs

bull Leaching fraction (Lf) is the fraction of the total applied water that passes below the root zone

bull The purpose of this study was to gain knowledge of the current leaching fractions achieved in south Delta soils under alfalfa culture

Research Project Leaching Fractions Achieved in South Delta Soils

under Alfalfa Culture (2013‐2015)

Site Water Source Soil Series

1 San Joaquin River Merritt silty clay loam

2 Old River Merritt silty clay loam


4 Middle River Merritt silty clay loam

5 Paradise Cut Grangeville fine sandy loam

6 Grant Line Canal Grangeville fine sandy loam

7 North Canal Ryde clay loam

Results 2013 2014

Site RZ Dep ECedagger ECw Lf RZ

Dep ECedagger ECw Lf

(cm) (dSm) (dSm) () (cm) (dSm) (dSm) () 1 100 112 054 3 120 98 054 3

2 150 141 074 3 130 98 088 5

3 140 14 057 21 140 12 040 18

4 150 95 047 3 120 107 057 2

5 130 36 178 25 130 41 193 26

6 120 81 085 6 130 98 087 5

7 140 31 036 7 150 38 049 8

daggerSalinity of the soil saturated paste at the base of the root zone Seasonal average applied water salinity

Results Soil Salinity ndash Site 1 ndash Silty Clay Loam

Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180

Soil ‐ Spring 2013

Groundwater ‐ Spring 2013

Soil ‐ Fall 2013

Groundwater ‐ Fall 2013



Soil ‐ Fall 2014




bull Soil salinity increased from spring to fall in both 2013 and 2014 bull Shallow spring groundwater appeared to be impairing leaching

Site

3 ndash

Silty Clay

Loa

m


Groundwater ‐ Spring 2013 Dep

th (cm)

Soil ‐ Fall 2013




Soil ‐ Fall 2014






Soil ‐ Fall 2013



Groundwater ‐ Spring 2014 150 180 210 240

Soil ‐ Fall 2014


Site

2 ndash

Silty Clay

Loa

m

Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180

ECe (dSm) 0 1 2

0 30 60 90

120

14 16 18

3 4

Dep

th (cm) Results

Soil Salinity ndash Site 5 ndash Fine Sandy Loam ECe (dSm)

0 2 4 6 Soil ‐ Spring 2013

0 Groundwater ‐ Spring 2013

Soil ‐ Fall 2013 30 Groundwater ‐ Fall 2013

60 Soil ‐ Spring 2014

Groundwater ‐ Spring 2014 90 Soil ‐ Fall 2014

Groundwater ‐ Fall 2014 120 Soil ‐ Spring 2015

Groundwater ‐ Spring 2015 150

180

bull Highest seasonal applied water salinity but lower root zone salinity compared to other sites This soil was more easily leached than the clay loam soils

Results 2013 2014

Number of Annual Yield Number of Annual Yield

Site Cuttings (tonsacre) Cuttings (tonsacre) 1 6 82 6 56

2 6 119 6 93

3 6 83 7 44

4 6 81 6 54

5 5 98 5 92

6 6 104 6 82

7 6 84 6 78

Conclusions bull Salinity is a problem in the Delta because soils have low

permeability surface irrigation water may be degraded saline groundwater is shallow and elevation is below sea level

bull Under current water quality conditions data illustrate that achieved leaching fractions are low and salts are building up in the soil to levels that have the potential to reduce crop yields

bull The Deltarsquos unique growing conditions and best management practices put constraints on growersrsquo ability to leach salts

bull Salinity will continue to impact Delta agriculture especially under conditions of limited water supplies or higher surface water salinity

STATEMENT OF JACK ALVAREZ IN SUPPORT OFSOUTH DELTA WATER AGENCYrsquoS OPPOSITION TO

THE SEDrsquos PROPOSED CHANGES TO THE SOUTHERN DELTA WATER QUALITY OBJECTIVES FOR THE PROTECTION OF

AGRICULTURAL BENEFICIAL USES

My name is Jack Alvarez I am a Board member of the South Delta Water Agency and a

Board member of the West Side Irrigation District (WSID) The latter is currently in the process

of merging with the Byron Bethany Irrigation District

I have been farming in the southern Delta for 35 years at various locations My family

has been farming in this area for 85 years Over the years we have and continue to grow a

number of crops including alfalfa cannery tomatoes and lima beans and others

From my position as Board member of SDWA and WSID I am regularly briefed on

southern Delta water quality and am aware that the current standards to protect agriculture

beneficial uses are 07 EC from April through August and 10 EC from September through

March Both of theses standards are regularly exceeded but the SWRCB for some reason has

made no effort to enforce them

I am also aware that the SED being discussed at this hearing proposes to relax the

standards to 10 EC year round I also understand that the proposed implementation of this new

standard seeks to maintain the 07 EC at Vernalis (from April through August) in an attempt to

maintain current conditions in the southern Delta hoping that this will mean the new standards

do not result in any further deterioration of the current conditions

The purpose of my statement is to challenge the underlying assumption of the SED that

the current conditions are protective of agricultural beneficial uses in the southern Delta That

assumption is demonstratively incorrect

Page -1-

I farm lands within WSID which receive water from Old River from an intake which is

upstream of the Tracy Old River temporary rock barrier site I also farm lands within

Banta-Carbona Irrigation District which for the most part receive water from the San Joaquin

River just downstream of Vernalis The Old River water is of worse quality than the San

Joaquin River water Based on my personal knowledge and records my crop yields for cannery

tomatoes and lima beans are clearly lower on my lands irrigated with Old River water than those

irrigated with the San Joaquin water (from the BCID diversion site)

Any comparison of crop yields is difficult given that no two locations can have the exact

same conditions However my lands are of similar soil types and I practice the same

management practices I believe it is clear that the difference in supply water quality is the only

major difference between the two lands and therefore conclude that the current water quality

conditions in the southern Delta are not protecting agriculture

I am aware of no efforts by the SWRCB to actually investigate salinity impacts to

agricultural in the southern Delta other than the report it relies upon to support the SED (with

regard to the salinity standards) authored Dr Hoffman As being explained by SDWAs counsel

Mr Herrick Mr Hoffman apparently used tile drainage data in his leaching calculations derived

from tiles drains in areas in and around the WSID service area I am personally aware of the

drains from which this data came These drains mostly intercept poor quality groundwater

They do not solely intercept excess applied water Hence if Dr Hoffman believed the tile drain

data was an indication of salts leaching out of the root zone he made a serious mistake The tile

drain data is an indication of the ground water quality it is not an indication of the salts leaching

through the overlying root zones

Page 2 of 3

I and certainly almost every other southern Delta farmer believe that the current water

quality conditions in the southern Delta are regularly detrimental to our crops We strongly

oppose any relaxation of these standards especially the 07 EC standard from April through

August We also believe the SWRCB should enforce the current standards

JACK ALVAREZ

Page 3 of 3

Leaching Fractions Achieved in South Delta Soils under Alfalfa Culture Project Report Update December 2016

Project leader Michelle Leinfelder-Miles Farm Advisor University of California Cooperative Extension San Joaquin County 2101 E Earhart Ave Ste 200 Stockton CA 95206 phone 209-953-6120 fax 209-953-6128 email mmleinfeldermilesucanredu

Executive summary

The Sacramento-San Joaquin River Delta region is a unique agricultural region of California While the region is named for its waterway configuration the Delta is also unique for its fertile soils and of the 738000 total acres approximately 500000 acres of the Delta are farmed In 2012 alfalfa was the second most widely grown crop in the Delta at approximately 72000 acres

Delta farming is challenged however by salinity which can stress crops and reduce yields In the Delta applied water contains salt and as water is evaporated and transpired ndash known as evapotranspiration ndash salts accumulate in the root zone In general plants are stressed by saline conditions because they must expend more energy to take up water leaving less energy for plant growth This trade-off is challenging in alfalfa production because the marketed crop is the vegetative growth and extra energy to take up water reduces hay yields To prevent this trade-off the root zone must be leached to maintain salts below crop tolerance thresholds This is accomplished by applying water in excess of that used by evapotranspiration The leaching fraction is the fraction of the total applied water that passes below the root zone The leaching requirement is the minimum amount of the total applied water that must pass through the root zone to prevent a reduction in crop yield from excess salts

Two factors establish the leaching requirement the salt concentration of the applied water and the salt sensitivity of the crop Alfalfa is moderately sensitive to salinity and is irrigated with surface water in the Delta thus the quality of surface water in the Delta affects growersrsquo ability to maintain yields Currently state policy surface water salinity objectives for the south Delta are set at levels meant to sustain agricultural yields based on crop tolerances of salt-sensitive crops Salinity levels however vary over space and time and salinity objectives may be exceeded during certain times of the year

The objective of this work was to gain knowledge on the current leaching fractions being achieved in south Delta alfalfa soils and update the state of knowledge on how surface water quality and rainfall affect the leaching fraction Seven south Delta alfalfa fields were selected for this study representing three soil textural and infiltration classes All seven sites had different sources for irrigation water Our results show that leaching fractions ranged from 2-26 percent with five of the seven sampling sites having a leaching fraction at or below 8 percent Alfalfa yield declined from the first to second year of this study We could not directly attribute the yield declines to salinity but long-term productivity of these sites could be diminished if

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salts continue to accumulate in the soil Since winter rainfall for leaching is unpredictable it is important to maintain good quality surface water for irrigation in the south Delta

Introduction related research and objectives

The Sacramento-San Joaquin River Delta region ndash for its soil type climate and water sources ndash is a unique agricultural region of California Diverse crops grow in the Delta region but alfalfa is a particularly important one According to the Agricultural Commissioners of the five-county Delta region alfalfa was grown on approximately 72000 acres in the Delta in 2012 making it the second most widely grown crop (Office of the Agricultural Commissioner 2012) Approximately 46000 of those acres were located in the San Joaquin County portion of the Delta The south Delta ndash an area southwest of Stockton CA ndash was reported by Hoffman (2010) to include approximately 110000 irrigated acres in 2007 Of those acres approximately 33000 were planted to alfalfa

Border check flood irrigation using surface water is the primary method of irrigating Delta alfalfa As a forage crop the marketed product of alfalfa is the vegetation or alfalfa hay Hay yields are directly related to crop evapotranspiration (ET) or the water transpired by the crop plus the water evaporated from the soil (Hanson et al 2008) As crop ET increases so does alfalfa yield up to maximum ET Nevertheless agronomic and economic principles constrain this relationship A particularly important constraint is Phytophthora root and crown rot disease Irrigation must be managed properly due to the susceptibility of alfalfa to Phytophthora It is a common disease and occurs in poorly-drained soils or when the water application to meet the crop water requirement exceeds the capacity of the soil to take in water It can be devastating for growers because the spores are mobile in water and have the ability to infect large areas of fields If infection stays in the roots plant growth will be reduced at best and plants may become susceptible to secondary infections If the infection spreads to the crown of the plant ndash the region of the plant from which stems sprout ndash the plant generally dies (Davis and Frate 2016)

In the Delta region soil salinity can also affect the relationship between ET and alfalfa yield In general plants are stressed by saline conditions because they must expend more energy to take up water leaving less energy for plant growth This can cause plant stunting and reduced yields To prevent harmful accumulation of salts the soil profile must be leached periodically with an amount of water in excess of what is used by plant ET Leaching occurs whenever irrigation and effective rainfall or the amount of rainfall that is stored in the root zone and available for crops exceed ET (Hoffman 2010)

The leaching fraction (Lf) is the fraction of the total applied water that passes below the root zone This can be expressed as

Lf = ECwECdw (Equation 1)

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where ECw is the electrical conductivity of the applied water and ECdw is the electrical conductivity of the drainage water at the bottom of the root zone which is equal to 2ECe (Ayers and Westcot 1985) The leaching requirement (Lr) is the minimum amount of the total applied water that must pass through the root zone to prevent a reduction in crop yield from excess salts Rhoades (1974) proposed the following equation for the Lr

Lr = ECw(5ECet ndash ECw) (Equation 2)

where ECet is the average soil salinity as measured by saturated paste extract that a crop can tolerate Thus there are two factors necessary to estimate the Lr One factor is the salt concentration of the applied water which can vary substantially in the Delta based on time of year and location The other factor is the salt tolerance of the crop Some crops are more tolerant of salinity than others alfalfa is moderately sensitive Beyond an average root zone soil salinity threshold (ECet) of 20 dSm and an average applied water salinity threshold (ECw) of 13 dSm alfalfa yield reductions are expected (Ayers and Westcot 1985) Using these values in Equation 2 the Lr is calculated to be 15 percent When ECet is given at 20 dSm but ECw ranges from 05-20 dSm the Lr ranges from 5-25 percent (Figure 1) The average ECw for this range of values is 13 dSm and the average Lr is 15 percent The yield potential guidelines in Ayers and Westcot (1985) assume a 15 percent Lf Using these guidelines to predict crop response from a given applied water salinity requires an achievable Lf of 15 percent and when ECw is higher than 13 dSm the Lf must be higher than 15 percent

Figure 1 Alfalfa leaching requirement (Lr) as a function of the applied water salinity (ECw)

Excess soil salinity in the Delta is a sporadic problem in the short term ndash varying with the depth and quality of the groundwater quality of the surface irrigation water and volume of effective winter rainfall Given the Deltarsquos unique circumstances and constraints a 15 percent Lf may not be possible Water tables in the area are typically within 2 meters of the soil surface and the groundwater quality may be near or worse than the threshold ECw of 13 dSm Additionally alfalfa is often grown on soils with a low water infiltration rate and as a perennial crop it has a high ET demand generally over 48 inches annually (Hanson et al 2008 Hoffman 2010) It can

3 | P a g e

be difficult to apply enough water to meet the ET and leaching requirement of alfalfa on low permeability soils If it is not possible to apply enough water to achieve a 15 percent Lf due to poor soil permeability proximity of groundwater or other agronomic considerations lower salinity irrigation water may be necessary to maintain yields Thus soil salinity will continue to be an issue in the Delta in the long run especially under conditions of a higher surface water salinity objective

The California State Water Resources Control Board (SWRCB) adopts water quality objectives for the protection of various beneficial uses in the Bay-Delta including agricultural uses An agricultural objective was first developed by the SWRCB in the 1978 Water Quality Control Plan which was not formally adopted until the 1995 Water Quality Control Plan and not implemented until the 2000 Water Rights Decision D-1641 The objective was determined using knowledge of the soil types irrigation practices and salinity standards of predominant crops in the area (Ayers and Westcot 1985) In particular the objective was based on the salt sensitivity of beans and alfalfa and the maximum applied water salinity that would sustain 100 percent yield potential for these crops Since beans were the most salt sensitive summer crop the objective for the months of April through August was set at 07 mmhoscm (equivalent to dSm) and the objective for the months of September through March was set at 10 mmhoscm based on the sensitivity of seedling alfalfa When the SWRCB adopted the 2006 Water Quality Control Plan no changes were made to the original 1995 Plan objectives because there was a lack of scientific information to justify a change (Hoffman 2010)

The objective of this work was to gain knowledge on the current leaching fractions being achieved in south Delta alfalfa soils and update the state of knowledge on how surface water quality and rainfall affect leaching The knowledge gained from this study provides current data to inform water policy that sets south Delta salinity objectives and it will assist growers with irrigation strategies for effective salinity management

Methods

The study was conducted in seven commercial fields of mature alfalfa in the south Delta region South Delta alfalfa fields were selected for their soil textural and infiltration characteristics and differing irrigation source water In particular the Merritt Ryde and Grangeville soil series were of interest These three soil series characterize over 36000 acres of the south Delta (24580 acres of Merritt silty clay loam 7780 acres of Grangeville fine sandy loam and 3691 acres of Ryde clay loam) (Hoffman 2010) Merritt and Ryde soils have a low saturated hydraulic conductivity (Ksat) approximately 10 mmhr in the top 124 cm and 70 cm respectively (NRCS 2014) The Grangeville series has a moderate Ksat of 101 mmhr in the top 152 cm (NRCS 2014) While the Grangeville and Ryde series are not as widespread in the south Delta as the Merritt series having soils of different textural classes and permeabilities was of interest for understanding how soil characteristics influence leaching fractions

4 | P a g e

Irrigation water for these seven sites is sourced from the San Joaquin River including Old River Middle River and connecting canals and sloughs Water quality from these sources varies temporally with flows but also spatially depending on tidal and current influences

Soil and groundwater sampling Modified procedures of Lonkerd et al (1979) were followed for sampling Spring soil samples were collected after most seasonal rainfall had ceased and before irrigations commenced in March and April of 2013 2014 and 2015 Before sampling holes were augured and the soil was visually assessed for its representation of the Merritt Ryde or Grangeville classifications Once visually confirmed as representative soil samples were collected from one border check per field Each check was divided into ldquotoprdquo ldquomiddlerdquo and ldquobottomrdquo sections where the top of the field was where irrigation water entered and the bottom was where irrigation water drained These three sections were distinguished because it was suspected that irrigation management andor soil variability would result in leaching differences from the top to the bottom of the check

Three replicate holes were augered (45-cm diameter) each from the top middle and bottom sections The holes were augured in 30-cm increments to a depth of 150-cm The three replicate-depths from the top middle and bottom sections were composited into one bulk sample thus there were 15 bulk samples collected from each field Bulk samples were oven-dried at 38 degrees C and ground to pass through a 2-mm sieve

At the same time that bulk soil samples were taken soil moisture samples were also collected using a volumetric sampler (60-cm3) These samples were collected from the center 7 cm of each 30-cm depth increment After extracting the soil it was sealed in a metal can to prevent moisture loss The soil was weighed before and after oven-drying at 105 degrees C for 24 hours and the soil moisture content (as a percent of the soil volume) was calculated

Groundwater samples were collected by auguring until water was visually or audibly reached The water was allowed to equilibrate in the hole before measuring the depth to groundwater and collecting a sample (200-mL) Samples were taken from the top middle and bottom sections Water was stored in a cooler (37 degrees C) until analyzed

The procedures for soil and groundwater sampling were again followed in October 2013 and 2014 after irrigations ceased for the season

Irrigation water sampling Water samples (200-mL) were collected when irrigation water was applied during the 2013 and 2014 irrigation seasons Water was collected at the top of the field from the source pipe or ditch Water samples were vacuum-filtered for clarity and stored in a cooler (37 degrees C) until analyzed Growersrsquo irrigation frequency varied among the sites water was collected from each site 5-8 times throughout the irrigation seasons (April-October)

Precipitation We used California Irrigation Management Information System (CIMIS) data averaged between the Manteca and Tracy locations for the 2014-2015 precipitation season as

5 | P a g e

the water applied as rainfall Data from these two locations were averaged because the seven field sites were located near these stations

Soil and water analysis Soil salinity was determined by measuring the electrical conductivity (EC) and chloride (Cl) ion concentration of the saturated paste extract where higher EC and Cl indicate higher levels of dissolved salts in the soil To conduct these procedures a saturated paste extract was made by saturating a soil sample with deionized water until all pores were filled but before water pooled on the surface (Rhoades 1996) When saturation was achieved the liquid and dissolved salts were extracted from the sample under partial vacuum The EC of the saturated paste extracts (ECe) and of the irrigation (ECw) and groundwater (ECgw) were measured in the laboratory of UC Cooperative Extension in San Joaquin County using a conductivity meter (YSI 3200 Conductivity Instrument) Chloride in the saturated paste extracts (Cle) and of the irrigation water (Clw) and groundwater (Clgw) was measured at the UC Davis Analytical Laboratory by flow injection analysis colorimetry (httpanlabucdaviseduanalysessoil227)

Alfalfa yield sampling Yield samples from each field were collected from the first a middle and the last cutting during the 2013 and 2014 growing seasons to investigate salinity effects on yield Three 025-m2 quadrat samples were taken from each of the top middle and bottom sections of the field Plants were cut approximately 5-cm above the ground level bagged and weighed for fresh weight Plants were then dried in an oven at 60 degrees C for 48 hours and weighed for dry weight Average annual yield was calculated by averaging all quadrat samples across all field sections and cuttings then multiplying by the total number of cuttings as reported by the grower

Calculations and analysis The equation Lf = ECwECdw was used for the leaching fraction calculation where as previously described ECdw is the electrical conductivity of soil water draining below the root zone and ECw is the electrical conductivity of the applied water (Ayers and Westcot 1985) We used the equation ECdw = 2ECe (Ayers and Westcot 1985) to relate known soil saturated paste extract salinity (ECe) to ECdw In previous research Lonkerd et al (1979) did not use this relationship but instead multiplied by a ratio of FCSP where FC is the field capacity of the soil and SP is the saturation percentage This ratio makes the assumption that soil water content below the root zone is at field capacity We did not make this assumption given the presence of a fluctuating water table and because soil moisture calculations demonstrated that not all soils were at field capacity when collected (data not shown) The 30-cm increment with the highest ECe in the fall was considered the bottom of the root zone for the Lf calculation and represents the salt concentration of deep percolation water from the bottom of the root zone This is supported by Bali et al (2001) who found that most alfalfa roots are growing in soil layers above the highest soil salinity The achieved Lf was calculated as both Lf = ECw2ECe and Lf = Clw2Cle where ECw and Clw are the average irrigation water salinity over the season and 2ECe and 2Cle are the salinity of the soil water near field capacity (Ayers and Westcot 1985) Data for the top middle and bottom sections were averaged to one Lf per site

6 | P a g e

Results and Discussion

Irrigation and groundwater salinity Over the 2013 and 2014 irrigation seasons average ECw ranged from 036-193 dSm across the seven sites and average Clw ranged from 142-914 meqL (Table 1) These averages include applied water as rainfall that fell either after spring soil sampling or before fall soil sampling as applicable for each site In both years three out of seven sites (Sites 2 5 and 6) had a seasonal average ECw exceeding 07 dSm the irrigation season salinity objective set by the California State Water Resources Control Board

Groundwater depth and salinity varied from spring to fall in both years (Table 2) Average groundwater depth ECgw and Clgw represent the average across top middle and bottom field sections at a site Average groundwater depth ranged from 102-232 cm across the two years and seven sites Average ECgw ranged from 23-143 dSm across the two years and seven sites and average Clgw ranged from 76-1087 meqL

Table 1 Irrigation water salinity as electrical conductivity (ECw) and chloride ion concentration (Clw) at seven south Delta alfalfa sites from April to October in 2013 and 2014

2013 2014

ECw (dSm) Clw (meqL) ECw (dSm) Clw (meqL)

Site Water Source Range Avg Range Avg Range Avg Range Avg

1 San Joaquin River 02-07 058 07-39 276 02-07 054 04-36 222

2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232

Table 2 Average groundwater depth (Dep) electrical conductivity (ECgw) and chloride ion concentration (Clgw) across seven south Delta alfalfa sites in spring and fall 2013 and 2014

Spring 2013 Fall 2013 Spring 2014 Fall 2014

Dep ECgw Clgw Dep ECgw Clgw Dep ECgw Clgw Dep ECgw Clgw

Site (cm) (dSm) (meqL) (cm) (dSm) (meqL) (cm) (dSm) (meqL) (cm) (dSm) (meqL)

1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e

Soil salinity Soil salinity is illustrated by depth (Figure 2) and depicted as average root zone salinity (Tables 3 and 4) At Site 1 (Figure 2A) soil salinity reached its highest at the 90-120 cm-depth increment at every sampling except the Spring 2015 sampling This was also the depth of groundwater in the spring of each year Thus it would appear that salts accumulated between 90 and 120 cm because groundwater limited leaching below this depth At Site 2 (Figure 2B) shallow fluctuating groundwater also appeared to be influencing the soil salinity profile albeit with a different pattern than at Site 1

Merritt silty clay loam is the soil series that characterizes Sites 1-4 and is a low permeability soil At Sites 1 2 and 4 (Figures 2A 2B and 2D respectively) the maximum salinity in the profile ranged from about 8-14 dSm depending on sampling date The maximum salinity was sometimes as shallow as the 60-90 cm-depth increment Similarly in the Imperial Valley where alfalfa is grown on low permeability soils Bali et al (2001) found that most root growth was in the top 90 cm when soil salinity reached its maximum (12 dSm) between 90 and 120 cm Thus the base of the root zone is where salinity reaches its maximum in the profile In the same study Bali et al (2001) also found that the alfalfa crop coefficient used to calculate crop water use was smaller in the saline conditions of the Imperial Valley compared to other regions in the southwestern states Since crop ET is correlated with alfalfa yields this suggests that yields may have been higher under lower salinity conditions This has implications for these Delta sites where low permeability soils and shallow groundwater also appear to be impairing leaching

Sites 5 and 6 (Figures 2E and 2F respectively) are both characterized by the soil series Granville fine sandy loam which has higher permeability than the Merritt series Average root zone salinity at Site 5 was low relative to Sites 1 2 4 and 6 It increased from Spring 2013 to Fall 2014 but then decreased in Spring 2015 reflecting higher winter rainfall in 2014-15 compared to 2013-14 (approximately 22 cm and 15 cm respectively) The salinity profile of Site 6 resembled that of Site 1 more than it did Site 5 Two possible explanations may explain the different soil salinity profiles between Sites 5 and 6 First while Site 5 had the highest applied water salinity of all seven sites it also had the highest leaching fractions (Table 5) Because of the sandy loam texture and higher permeability the grower was able to apply more water to the field without agronomic consequences thus leaching salts deeper into the profile The higher ECgw of Site 5 may be reflective of salts leaching through the soil profile and accumulating in the groundwater Second the soil salinity profiles of the top middle and bottom sections of Site 6 (data not shown) illustrated that the top section of the field had a salinity profile similar to that of Site 5 but the middle and bottom sections had much higher salinity More leaching was occurring on the top section of the field compared to the middle and bottom sections Because Site 6 is also a sandy loam the grower may be able to manage soil salinity better by affording a longer opportunity time for irrigation water to infiltrate the middle and bottom sections without agronomic consequences This type of management may not be wise on low permeability soils if longer opportunity time results in standing water and anaerobic conditions on the middle and bottom sections

8 | P a g e

The salinity profiles at Sites 3 and 7 were the lowest of all seven sites (Figures 2C and 2G respectively) At Site 3 the sampling profile never reached an ECe of 20 dSm at any sampling date At Site 7 the salinity was generally low but increased by Fall 2014 Application of low salinity water may explain the low soil salinity down these profiles however these fields were also observed to be the weediest fields of the seven sites and were disked in because of low productivity at the end of Fall 2014 (Hence there is no data for Spring 2015) Site 3 had high leaching fractions and Site 7 had moderately high leaching fractions relative to Sites 1 2 4 and 6 The amount of applied water at these sites may have leached salts with the consequence of anaerobic conditions on these low permeability soils reducing stand quality with weed infestation

9 | P a g e

A

C

E

G

D

B

F

Figure 2 Soil salinity as electrical conductivity of the soil saturated paste (ECe) by depth and groundwater depth and salinity Curves are the average ECe values across top middle and bottom sections of the field (average of nine samples)

10 | P a g e

Table 3 Average root zone salinity down the soil profile (ECe dSm) for seven south Delta alfalfa sites across 2013-2015

Average Root Zone ECe (dSm)

Site Spring 2013 Fall 2013 Spring 2014 Fall 2014 Spring 2015

1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data

Table 4 Average root zone salinity down the soil profile (Cle meqL) for seven south Delta alfalfa sites across 2013-2015

Average Root Zone Cle (meqL)


1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data

With the possible exception of salt-tolerant varieties (Cornacchione and Suarez 2015) the average root zone salinity for maintaining 100 percent yield potential is an ECe of 20 dSm (Ayers and Westcot 1985) or Cle of 20 meqL (Tanji 1990) Average root zone salinity of five of the seven sites exceeded the ECe thresholds in all five of the samplings across the three years (Table 3) Four sites exceeded the Cle thresholds across the three years (Table 4) The difference was that Site 5 had average ECe values that were slightly above the threshold but Cle values that were slightly below the threshold Some of the study sites likely accumulated salts because shallow groundwater impeded salts from leaching out of the root zone or low permeability soil impaired leaching Only Sites 3 and 7 had average root zone salinity consistently below the ECe and Cle thresholds

Overall four out of seven sites had an ECe that met or exceeded 6 dSm at the 90 cm depth on all sampling dates This illustrates that salinity may build up in soil layers just below the depth which is typically sampled for soil nutrient and salinity status approximately the top 60 cm (Meyer et al 2008) Thus over time growers may not be aware of the degree to which soil salinity is increasing in their fields

11 | P a g e

Leaching fraction The Lf of the water percolating from the bottom of the root zone was calculated for both EC and Cl (Table 5) and the data were highly correlated (R2 = 096) Only two sites (Sites 3 and 5) had a Lf that exceeded 15 percent which is the Lf assumed in crop tolerance tables that predict alfalfa yield declines at ECe and ECw values greater than 20 dSm and 13 dSm respectively (Ayers and Westcot 1985) Site 7 had moderate leaching compared to Sites 1 2 4 and 6 which all had inadequate leaching While a 15 percent Lf is a general rule of thumb in agricultural systems given the Deltarsquos unique circumstances and constraints a 15 percent Lf may not always be possible Soil permeability may be low water tables are typically around 2 meters from the soil surface and groundwater quality may be near the salinity thresholds for maintaining crop yield potential Additionally as a perennial crop alfalfa has a high annual ET demand It can be difficult to apply enough water to meet the ET and Lr to maintain yields particularly on low permeability soils like those in the south Delta

While management could have improved leaching at Site 6 as previously described results from leaching studies in the Imperial Valley suggest that management cannot always improve leaching on low permeability soils with shallow groundwater In a location where a shallow saline aquifer was the source of soil salinity Grismer and Bali (1996) continuously ran shallow well pumps for three years discharging into surface drainage canals in an effort to lower the groundwater level and reduce soil salinity Under typical cropping and irrigation practices groundwater level was lowered but soil salinity did not significantly change Ponding water on the site for one month however did result in decreased soil salinity In a separate study Grismer and Bali (1998) found that existing and augmented subsurface drainage systems were no more effective at managing salinity than deep ripping clay soils for better water penetration Because alfalfa is a perennial crop that typically grows for four or more years in the Delta the management practices that lowered soil salinity in these studies ndash ponding and deep ripping ndash are only possible when rotating out of alfalfa Thus maintaining high quality surface irrigation water is important for maintaining Delta alfalfa production

Table 5 Root zone depth (RZ Dep) soil salinity (ECe Cle) and leaching fraction (Lf) at the base of the root zone at seven south Delta alfalfa sites in Fall 2013 and 2014 averaged across top middle and bottom field sections

2013 2014

Site RZ Dep ECe Cle Lf RZ Dep ECe Cle Lf

(cm) (dSm) (meqL) EC () Cl () (cm) (dSm) (meqL) EC () Cl ()

1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e

Yield Alfalfa yield is presented in Table 6 Across California alfalfa yields reach 8-10 tonsacreyear on average (Orloff 2008) Average yield at all seven sites reached or exceeded this range in 2013 but four sites did not reach this average range in 2014 and all sites showed a decrease in yield While previous work has illustrated linear decreases in yield as average root zone salinity increases (Bower et al 1969 Shalhevet and Bernstein 1968) alfalfa yield was not correlated with average root zone salinity in this study Because this project was not a replicated experiment with imposed treatments but rather involved surveying current conditions other sources of variability that affect yield ndash like pest pressure or stand quality among others ndash could not be statistically controlled Thus a statistical relationship between salinity and yield was not evident

Table 6 Alfalfa yield averaged across cuttings and field sections at seven Delta sites in 2013 and 2014

2013 2014

Number of Annual Yield Annual Yield Number of Annual Yield Annual Yield

Site Cuttings (tonsacre) (Mgha) Cuttings (tonsacre) (Mgha)

1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary

The Sacramento-San Joaquin River Delta region is a unique agricultural region of California that is challenged by salinity Leaching is the primary means of managing salinity and must be practiced when there is the potential for salinity to impact yield In 2013-2015 seven alfalfa fields in the Sacramento-San Joaquin River Delta region were monitored for irrigation water groundwater and soil salinity Results illustrate the inherent low permeability of certain Delta soils the build-up of salts in the soil to levels that have the potential to affect crop yields and a low achieved Lf The Deltarsquos unique growing conditions including low permeability soils and shallow groundwater coupled with unpredictable winter rainfall put constraints on growersrsquo ability to manage salts by leaching and achieve a Lf that meets the Lr to sustain crop yields While salinity and yield were not statistically correlated in this study salinity at these sites is increasing down the soil profile to unsuitable levels which could compromise alfalfa yields in the future preclude the growing of other salt-sensitive crops or reduce agricultural longevity of these fields Thus salinity ndash a pervasive issue in the Delta ndash will continue to impact Delta agriculture especially under conditions of higher surface water salinity

In future reporting rainfall from the 2014-15 winter season will be incorporated into the analysis Recent studies have emphasized the importance of rainfall for leaching (Platts and Grismer 2014 Weber et al 2014) suggesting that irrigation water during the season cannot

13 | P a g e

substitute for low winter rainfall Low winter rainfall results in inadequate leaching unless other measures are taken such as replenishing the soil profile with irrigation water after harvest in the fall (Weber et al 2014) or irrigating before a storm in order to leverage the rainfall and optimize winter leaching Such measures may be necessary to sustain soil longevity and agricultural productivity in the Delta where the achieved Lf is low particularly in low rainfall years

Acknowledgements

The author wishes to acknowledge the California Institute for Water Resources and the South Delta Water Agency for project funding and Terry Prichard for project guidance and mentoring

References

Ayers R S and D W Westcot 1985 Water Quality for Agriculture FAO Irrigation and Drainage Paper 29 Rev 1 FAO United Nations Rome 174 p

Bali K M M E Grismer and R L Snyder 2001 Alfalfa water use pinpointed in saline shallow water tables of Imperial Valley California Agriculture 55(4) 38-43

Bower C A G Ogata and J M Tucker 1969 Rootzone salt profiles and alfalfa growth as influenced by irrigation water salinity and leaching fraction Agronomy Journal 61 783-785

Cornacchione MV and DL Suarez 2015 Emergence forage production and ion relations of alfalfa in response to saline waters Crop Science 55 444-457

Davis R M and C A Frate 2006 Alfalfa ndash Phytophthora root and crown rot UC IPM httpipmucdaviseduPMGr1101011html Viewed December 2016

Grismer M E and K M Bali 1996 Continuous ponding and shallow aquifer pumping leaches salts in clay soils California Agriculture 51(3) 34-37

Grismer M E and K M Bali 1998 Subsurface drainage systems have little impact on water tables salinity of clay soils California Agriculture 52(5) 18-22

Hanson B R K M Bali and B L Sanden 2008 Irrigating alfalfa in arid regions In C G Summers and D H Putnam (eds) Irrigated Alfalfa Management for Mediterranean and Desert Zones The Regents of the University of California Agriculture and Natural Resources Oakland CA p 89-111

Hoffman G J 2010 Salt Tolerance of Crops in the Southern Sacramento-San Joaquin Delta Final Report for the California Environmental Protection Agency State Water Resources Control Board Division of Water Rights January 5 2010

14 | P a g e

Meyer R D D B Marcum S B Orloff J L Schmierer 2008 Alfalfa fertilization strategies In C G Summers and D H Putnam (eds) Irrigated Alfalfa Management for Mediterranean and Desert Zones The Regents of the University of California Agriculture and Natural Resources Oakland CA

Lonkerd W E C F Ehlig and T J Donovan 1979 Salinity profiles and leaching fractions for slowly permeable irrigated field soils Soil Sci Soc Am J 43 287-289

Natural Resources Conservation Service (NRCS) United States Department of Agriculture Accessed 2014 Soil Survey Geographic (SSURGO) Database for San Joaquin County California Accessed via SoilWeb httpcasoilresourcelawrucdavisedudrupal node902

Office of the Agricultural Commissioner ndash San Joaquin Sacramento Yolo Solano and Contra Costa counties 2012 Pesticide use reports

Orloff S B 2008 Choosing appropriate sites for alfalfa production In C G Summers and D H Putnam (eds) Irrigated Alfalfa Management for Mediterranean and Desert Zones The Regents of the University of California Agriculture and Natural Resources Oakland CA p 19-29

Platts B E and M E Grismer 2014 Chloride levels increase after 13 years of recycled water use in the Salinas Valley California Agriculture 68 (3) 68-74

Rhoades J D 1974 Drainage for salinity control In J van Schilfgaarde (ed) Drainage for Agriculture Agronomy Monograph No 12 SSSA Madison WI p 433-461

Shalhavet J and L Bernstein 1968 Effects of vertically heterogeneous soil salinity on plant growth and water uptake Soil Science 106 85-93

Rhoades JD 1996 Salinity Electrical conductivity and total dissolved solids In Sparks D L A L Page P A Helmke R H Loeppert P N Soltanpour M A Tabatabai C T Johnston and M E Sumner (ed) 1996 Methods of soil analysis part 3 chemical methods Soil Science Society of America Inc and American Society of Agronomy Inc Madison WI

Tanji KK 1990 (ed) Agricultural salinity assessment and management ASCE manuals and reports on engineering practice No 71 Am Soc Civil Eng New York NY

US Salinity Laboratory Staff 1954 Diagnosis and Improvement of Saline and Alkali Soils Agriculture Handbook No 60 USDA US Government Printing Office Washington DC

15 | P a g e

Weber E S R Grattan B R Hanson G A Vivaldi R D Meyer T L Prichard and L J Schwankl 2014 Recycled water causes no salinity or toxicity issues in Napa vineyards California Agriculture 68 (3) 59-67

16 | P a g e

________________________________________

Brownell JamesWaterboards

From Jherrlawaolcom Sent Friday April 14 2017 407 PM To Brownell JamesWaterboards Cc Herrick John aolcom Subject SDWA Comments Basin Plan Amendment Salinity Objective

httpswwwdeltacagovregional_economyeconomic_sustainability

httpwwwwaterboardscagovcentralvalleywater_issuessalinitycentralvalley_salinity_alternatives_archivesinitial_devel opmentswrcb_02may06_ovrvw_rptpdf

JOHN HERRICK ESQ SOUTH DELTA WATER AGENCY 4255 Pacific Avenue Suite 2 Stockton CA 95207 (209) 956-0150 phone (209) 956-0154 fax

CONFIDENTIALITY NOTICE This electronic message is intended to be viewed only by the individual or entity to whom it is addressed It may contain information that is privileged confidential and exempt from disclosure under applicable law Any dissemination distribution or copying of this communication is strictly prohibited without our prior permission If the reader of this message is not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient or if you have received this communication in error please notify us immediately by return e-mail and delete the original message and any copies of it from your computer system

1

TESTIMONY OF ALEX HILDEBRAND HEARING ON PROPOSED CEASE AND DESIST ORDER TO

DWR AND USBR

My name is Alex Hildebrand I was a Director of the South Delta Water Agency (SDWA) for 30 years and am currently the engineer for that Agency A copy of the Agencyrsquos boundaries is provided as Attachment ldquoArdquo I have testified many times before this Board as well as other regulatory and legislative bodies and was qualified as an expert witness with regard to the water quality and flow issues affecting the South Delta

A copy of my current statement of qualifications is attached hereto as Attachment ldquoBrdquo Briefly I have a BS in physics with minors in chemistry and engineering and worked for Chevron until I retired in engineering and technical capacities including Assistant Chief Engineer of the Richmond Refinery and Director of the La Habra Research Laboratory Since that time I have farmed approximately 150 acres on the San Joaquin River about 12 miles by river downstream of Vernalis in the South Delta For the past 30 years I have been intimately involved in the discussions negotiations regulatory proceedings and litigation to protect its diverters from the adverse effects of SWP and CVP and to insure the area has an adequate supply of good quality water

My testimony for this proceeding is divided into four parts following a discussion of background The first part deals with how the DWR and USBR can meet current salinity standards while using temporary rock barriers It has been argued that the 07 EC requirement in internal channels cannot be reasonably met even after implementation of the SDIP and that it is therefore unreasonable to require it now That assertion is incorrect The second deals with the numerous interrelated benefits which result from compliance with permit conditions The third part explains how I and others are personally affected And the last part addresses the reconsideration of the Water Quality Response Plan

I Background

1) Regulatory Background

As set forth in the 1991 and 1995 Water Quality Control Plans the two San Joaquin River standards (at Brandt Bridge and Vernalis) were to be implemented promptly The two Old River standards (Old River near Middle River and Old River at Tracy Road Bridge) were to be implemented no later than December 31 1997 (see Attachment ldquoCrdquo) The 1995 Plan therefore recognized that the San Joaquin River standards would be addressed with good quality flows on the River while the Old River standards required other actions such as barriers which could not be immediately implemented

SDWA-2

In D-1641 the Board acknowledged that ldquoConstruction of permanent barriers alone is not expected to result in attainment of the water quality objectivesrdquo The Board went on to note that the ldquoobjectives can be met consistently only by providing more dilution or by treatmentrdquo (See Attachment ldquoDrdquo D-1641 at page 88)

Hence in 2000 this Board recognized that permanent barrier installation and operation and other actions including additional dilution flows were necessary to meet the standards

Since 1995 at the earliest and 2000 at the latest DWR and USBR have known that in order to meet the 0710EC standards they had to undertake actions in addition to the proposed barrier program To my knowledge DWR and USBR have undertaken no actions other than the barrier program

As I understand the issues before the Board in this proceeding the questions are first whether a Cease and Desist Order should issue and second if so what terms should be in such an order

The answer to the first question is certainly ldquoyesrdquo Since DWR and USBR do not believe their current operations including temporary barriers will result in compliance with their permit terms especially at the three interior South Delta stations they should be ordered to comply There appears to be no logical or practical reason for not requiring compliance with existing Water Quality Objectives and permit terms This is especially true given that the Board determined over five years ago in D-1641 that compliance would indeed require additional dilution flows (or treatment) The fact that DWR and USBR knew the permanent operable barriers would not be built in the short term and did not undertake the necessary and anticipated other actions to secure and provide additional flows or treatment does not change the need for the objectives or the benefits therefrom

I note that HR 2828 requires the USBR to develop a plan by the end of this year under which it will meet its water quality obligations on the San Joaquin River (see Attachment ldquoErdquo) Since the Congress believes the Bureau should meet the objectives one would think the SWRCB would too

2) Historical Background

The changes in San Joaquin River flows and water quality pre-CVP and post CVP are set forth in the June 1980 Report entitled ldquoEffects of the CVP Upon the Southern Delta Water Supply Sacramento - San Joaquin River Delta Californiardquo This Report and numerous other studies and investigations (including D-1641) have identified the operation of the CVP as the principle cause of the salinity problem in the lower San Joaquin River and Delta However the SWPrsquos effects on flows in Delta channels and its

2

joint efforts with the CVP in supplying export water to the San Joaquin Valley are significant contributory causes

As a consequence of this problem the SWRCB slowly adopted and even more slowly implemented water quality objectives to protect agricultural beneficial uses Currently only dilution water is used to meet the Vernalis standard The delay in implementing the other three standards has allowed DWR and USBR to avoid taking other actions [Although temporary barriers do trap some good quality export water which improves water quality in portions of Middle River and Tracy Old River compliance stations the net flow is back (downstream) over the barriers and the water quality does not approach the 07 EC standard

The dilution water needed to comply with the current Vernalis salinity objectives is required because the westside wetlands and farm lands receive Delta Mendota Canal (DMC) water which contains a large salt load That salt load is then concentrated by crop and wetland evaporation Most of the salt then drains to the river where it must be diluted

II Compliance with the 0710EC internal South Delta salinity standard with Temporary barriers

The subject Water Quality Objectives can be met and the in-channel water supply in internal South Delta channels can be maintained at 07 EC from April through August with very little water cost to the CVP and SWP This is the case both before and after permanent barriers are installed and other concurrent measures are provided While using temporary barriers the following salinity control measures and others should be utilized

1) Dilution Needs

A) As water passes Vernalis it slowly degrades due to evaporation consumptive uses and urban discharges This degradation is reflected in field data which DWR has collected and which is set forth in Attachment ldquoFrdquo The increase in salinity during low flows can be 1 EC or more from Vernalis to Brandt Bridge The amount of dilution water needed to offset this rise in salinity at Brandt Bridge or elsewhere depends on the quality of the dilution water and the amount of the flow from Vernalis to Brandt Bridge Dilution provided upstream of Vernalis can be used to lower salinity below 07 EC at Vernalis so that it will not rise above 07 EC at downstream locations Dilution with Middle River water can be used to restore salinity to 07 EC at the point of dilution To offset a 01 EC rise in salinity would take about 250 cfs of 04 EC dilution water when the Vernalis base flow is 1000 cfs The 04 EC is representative of DMC water quality If the dilution flow was provided from one of the tributaries less of that better quality

3

water would be required

2) Dilution Opportunities

A) New Melones is currently the only reservoir used by the USBR to meet the Vernalis standard Whatever additional measures are undertaken to meet the downstream South Delta standards the New Melones releases that would be required in the absence of these measures to meet the Vernalis standard will continue to be required at least in the short term Additional releases could also be made from this source to contribute to meeting the other South Delta standards This year as of June the Bureau has allocated 180000 acre-feet of New Melones storage for water quality purposes but has used none of this amount (see Attachment ldquoGrdquo personal communication with USBR staff) Obviously in the short term water is available from New Melones

B) Additional water from the tributaries to the San Joaquin River could be purchased for release during the April through August time frame In the recent past hundreds of thousands of acre-feet have been purchased from the tributaries for a variety of reasons As stated above it would take less of this high quality water to provide the needed dilution than is the case when DMC water is used

C) Upstream exchanges could also be coordinated to provide dilution flows Given the various connections of the SWP and CVP distribution systems exchanges between water users could be made to provide additional flows on the San Joaquin River For example this year excess and flood flows from Friant were diverted at the Mendota Pool for delivery to Westlands Water District and others Some of that water could have been allowed to flow downstream in exchange for other DMC California Aqueduct or San Luis Reservoir supplies

D) Water can also be recirculated through the DMC using one of its wasteways to deliver the flows to the San Joaquin River The Bureau conducted such a recirculation pilot project in 2004 using DMC water released from the Newman Wasteway The releases during that project had a significant impact on San Joaquin River quality (See Attachment ldquoHrdquo) The 250 CFS recirculation release from the Newman Wasteway decreased the EC in the River from 1200 to 900 ( or 12 to 09 using the same parameters as the 07 standard) at the Patterson Measurement Station and from 700 to 600 (or 07 to 06) at the Vernalis Station [The differing changes are due to the differing amounts of flow in the River at the two locations] I also note that D-1641 specifically required the Bureau to investigate the use of such recirculation to assist in meeting water quality standards I believe the Bureau has failed to meet the deadlines required by D-1641

E) Transfers for EWA or other purposes can be coordinated such that the transfer water could be released during the April - August time frame The transfer water

4

would provide dilution but would not be lost as San Joaquin River and South Delta diversion needs do not change with flow fluctuations

F) As the Board knows CVP permits in addition to New Melones are burdened with the requirement of meeting the salinity objectives Hence releases from Friant Shasta Folsom or San Luis could be used to supplement San Joaquin River flows For example the high flows this year from Friant re-charged (to some degree) the groundwater in the area at and above Gravelly Ford on the San Joaquin The Bureau missed a perfect opportunity to test how much water would be lost from additional summer releases once that groundwater had been re-charged

G) Temporary barrier operations result in net downstream flow back over the Middle River and Grant Line Canal barriers Improved San Joaquin River water quality will also improve the Middle River and Grant Line quality If this does not result in compliance at the Middle River and Old River Stations other actions can be undertaken The Middle River rock barrier can be improved to capture and retain more high tide water and low lift pumps can be added at the barrier to increase the flow of high quality water up through Middle River and into Old River This will maintain high quality water in Middle River and the flow continuing into Old River will blend with the water flowing into the head of Old River This will further reduce the salinity of the Old River water which is also reduced by the measures discussed above

3) Recovery of Dilution Flows

A) Any additional dilution flows added to the San Joaquin River are available for export as they pass through the South Delta If the water cannot be currently pumped as additional exports DWR and USBR could coordinate exchanges so that the water is pumped for such things as EWA purposes using the additional 500 CSF export authorization of the SWP or exchanged to replace or substitute for a transfer being accomplished under JPOD operations Even if none of these authorizations were available DWR and USBR could petition the Board for short term authorization to allow them to pump these additional dilution flows One would assume the Board would look favorably upon such a request given that its underlying purpose is to meet existing Water Quality Objectives Approval of such petition would be similar to D-1641s ldquono net lossrdquo principle regarding fishery releases In sum all additional dilution flows would enter the South Delta and be available for export at the SWP andor the CVP pumps The losses should only be minimal For example the recirculation pilot program estimated the losses at less than 10 I recall that carriage water losses for the DWR Dry Year Purchase Program were less than 5 in 2004

It is important to note that the water deliveries of the CVP to its westside service area of the San Joaquin Valley as assisted by the SWP are the cause of the Riverrsquos

5

salinity problems As I understand it other parties are asserting that the CVP and SWP should not be required to meet the standards if it adversely affects their deliveries or costs It would be illogical and unfair to allow the continued delivery of the water which causes the salt problem and yet not require that some of that delivered water be used to mitigate the salt problem

III Benefits Resulting From Compliance With The Salinity Objectives

I will now give an overview of the benefits from meeting the Water Quality Objectives which also addresses the question of whether a Cease and Desist Order should issue

A) As the Board knows the 0710 EC standards were developed to protect agricultural beneficial uses The voluminous studies investigations and testimony previously used by the Board in setting these standards was referenced in SDWArsquos presentation at the Periodic Review process workshops Generally ECrsquos above 07 have an incremental adverse effect on crop production which translates into a monetary damage to farmers

B) To get a broad estimate of the damage that occurs as the EC of the water rises I refer the Board to the previously submitted report of Dr G T Orlob attached hereto as Attachment ldquoIrdquo and entitled ldquoImpacts of San Joaquin River Quality On Crop Yields In The South Deltardquo Therein Mr Orlob calculated the crop damage in dollars between actual crop yields and the yields which would result if a standard of 500 TDS had been met Using 1976 figures and dollars the crop loss for the South Delta area was (1570 - 864) $706 million In 2005 dollars it is approximately $24 million (using a CPI calculation at httpwoodrowmplsfrbfedusresearchdatauscalc) This gives the Board a good idea of the scope of the crop damage if the EC downstream of Vernalis were allowed to exceed the current standard during the April through August time frame The specific impacts on diverters is exemplified by the testimony of the other SDWA and CDWA witnesses

C) We also know that virtually all of the San Joaquin River water ends up at the State and Federal pumps (see Testimony of Thomas Zuckerman Exhibit No CDWA-10) This is due to the fact that even with temporary barriers the net flow is downstream over the Grant Line and Middle River barriers and that the water which continues down the mainstem of the River also mostly ends up at the pumps Hence the quality of export water is partially dependent on the quality of the San Joaquin River Improving the River water quality in order to meet the standards will benefit export interests especially municipal water users Although I do not have the calculations I understand that the Bureau has done investigations which determined the benefit to municipal water treatment plants resulting from improvements and source water quality

6

D) The Board is also well aware of the dissolved oxygen (DO ) problem in both the mainstem of the River specifically in the Stockton Deep Water Ship Channel and also generally throughout the South Delta Two Basin Plan Objectives for DO apply to these waters Additional good quality water added to the system for purpose of meeting the salinity standards will also help improve DO levels both because of the quality of the flows and the additional flowcirculation they will provide

E) The additional flows would also provide benefits to the various fisheries We know that out-migrating salmon smolts are traveling through the system even after the spring pulse flow has ended These fish would be helped by the higher flows Other species such as steelhead and smelt may also be benefitted by the higher flows Use of the additional flows for dilution would provide an opportunity for the fishery agencies to examine the effects

IV Effects On Farming Operations

As I referenced above I am a farmer on the San Joaquin River I divert under both appropriative rights (see Attachment ldquoJrdquo) and under my riparian rights (my chain of title documents are being introduced by a CDWA witness as Exhibit No CDWA-6) I have personally experienced the adverse impacts of the SWP and CVP and other upstream projects I have had reduced crop yields due to high salinity of the River water I have been unable to divert from the River due to decreased upstream flows and the destruction of the high tide which previously extend to the portion of the River I abut Requiring the DWR and USBR to meet the previously established Water Quality Objectives which are contained in their permits would not only protect me but also numerous other beneficial users of water Farmers further downstream have experienced more loss due to salinity because salinity rises above the Vernalis standard as water flows downstream as previously discussed

Finally for clarification the draft Cease and Desist Order states the temporary barriers are installed to mitigate the adverse effects of the HOR fish barrier This is misleading Although the federal funding for the temporary barriers was previously linked in CVPIA to the funding for the HOR fish barrier as mitigation of that barrier that does not accurately describe why the other three tidal barriers are installed It is my understanding that DWR now shoulders all of the costs of the temporary barrier program though there may be some arrangement whereby USBR will pay its share in some other way The temporary tidal barriers are installed to partially mitigate the adverse effects on water levels quality and quantity resulting from the operations of the CVP and SWP At this date the SWRCB should not be trying to avoid describing the true state of affairs in the South Delta There is no disagreement that the projects lower water levels decrease flows reverse channel flows cause stagnant zones and worsen water quality The temporary tidal barriers are one of the preliminary steps in correcting these problems

7

V Water Quality Response Plan

Finally I will address this Boardrsquos reconsideration of the Chief of the Division of Water Rights approval of the current Water Quality Response Plan for Joint Point of Diversion In approving the current Response Plan the Division Chief waived compliance with the currently existing Water Quality Objectives for Agricultural Beneficial Uses at the Brandt Bridge Old River near Middle River and Old River at Tracy Road (sic) Bridge This would appear to be not only beyond the Division Chiefrsquos authority and contrary to D-1641 but also directly contrary to the purpose of the Water Quality Response Plan

D-1641 requires as a condition to JPOD that the DWR and USBR ldquodevelop a response plan to ensure that the water quality in the southern and central Delta will not be significantly degraded through operations of the Joint Point of diversion to the injury of water users in the southern and central Deltardquo (see for example page 150-151 of D-1641) Approval of the plan was to come from the Division Chief

The purpose of the plan is to ensure that the incremental affects on water quality resulting from JPOD do not injure other users Inexplicably the Division Chief decided that while she was protecting the Delta users from the incremental effects of JPOD on water quality she would relax the existing Water Quality Objectives In other words she allowed a greater impact to water quality than she was protecting through the plan

This bizarre decision by the Division Chief cannot stand and should be forthwith revoked No further evidence is necessary to undo such an act which is not only beyond her authority but directly contrary to the explicit and implicit purposes of the Water Quality Response Plan This Board will consider changes to the 1995 Water Quality Control Plan through the Periodic Review process and perhaps through the process resulting from DWR and USBRrsquos Petition to delay implementation of their permit terms The Response Plan process did not give any party notice that such a significant change was pending and so it would be unfair and wrong to allow it Similarly we belief a change in the standards would require new environmental evaluation

SDWA requests that the Water Quality Response Plan not include the Division Chiefrsquos wrongful waiver of existing standards

SDWACease and DesistHildebrand Testimony Cease and Desist

8

10_sdwa_comment

201704_com_sdwa_att1





Hildebrand Testimony

Hildebrand Exhibits

along a portion ofthe San Joaquin River a protection now nearly 20 years past due Generally salts (and boron) are the constituents in River water that can most affect agricultural plant growth and crop production Even though other constituents can have effects on crops the control of the salts will for the most part provide the necessary protection for agricultural dependant on River water supply

According to plant and soil science plant health and crop production are a function of the soil salinity Measuring or maintaining short term soil salinity is practically impossible and so the yearly ( or seasonal) soil salinity is used to estimate whether or not a particular crop is being affected Thus each crop has a predeterminedcalculated soil salinity threshold Once the soil salinity rises toabove that threshold damage to the plant and also to crop production increases Protection therefore is maintained by keeping the soil salinity below the threshold

Salts affect plant water uptake by interfering with the osmotic process by which plants take water into their rootsmiddot To maintain acceptable levels of salt in the soil enough water of a certain quality must pass through the soil in order to move salts out of the plant root zone This process is called leaching and the leaching fraction is the number given to the percentage of water passing through the soil Thus one can calculate the leaching fraction needed in order to pass the delivered salt ( delivered in the applied irrigation water) through the soil so salt does not build up and one can calculate the actual amount of leaching fraction occurring in any particular field

The ability ofwater to pass through a soil is dependent on a number offactors especially middotofcourse the permeabilityporosity of the soil Different soils have different permeabilities so leaching occurs at different rates in different places For example a sandy soil may pass water more easily than does a clay soil The problem is not simply solved applying more water to push the salts through the soil This is because some roots are susceptible to rot and disease if they are wet too long In other cases the management practices preclude longer or continuous irrigations Alfalfa fields must dry out in between some irrigations in order for mowing raking and baling to be done This means that the grower cannot simply irrigate longer in order to accomplish adequate leaching

With this background I will now explain the fundamental faults with the Hoffman approach The following is taken from the SOWA comments to the SWRCBs Draft SED examiningjustifying proposed relaxation of the southern Delta salinity standards The reader should not assume these duplicated comments are not germane to the subject issue as the comments show that absent reliable data the Hoffman approach is simply guessing and not a scientific examination

HOFFMAN REPORT

The basis for the SWRCB s proposed changes to the southern Delta water quality objectives is the January 2010 report by Dr Glenn Hoffman Salt Tolerances ofCrops in the Southern Sacramento-San Joaquin Delta (Hoffman Report) As related in the Hoffman Report impacts to crops are estimated to occur when the EC ofthe soil reaches a thresholdor any particular crop In additiorl individual applications ofhigh saline water can also adversely affect plants and crops even when the soil EC threshold is not reached The Hoffman Report uses no current data relies on no actual sampling and testing ofsoils and contains no actual














































Very truly yours

JOHN HERRICK

shy

+ bull


Alfalfa Culture




Stockton CA

December 16 2016



























Results 2013 2014




2 150 141 074 3 130 98 088 5

3 140 14 057 21 140 12 040 18

4 150 95 047 3 120 107 057 2

5 130 36 178 25 130 41 193 26

6 120 81 085 6 130 98 087 5

7 140 31 036 7 150 38 049 8



Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180



Soil ‐ Fall 2013




Soil ‐ Fall 2014





Site

3 ndash

Silty Clay

Loa

m



th (cm)

Soil ‐ Fall 2013




Soil ‐ Fall 2014






Soil ‐ Fall 2013




Soil ‐ Fall 2014


Site

2 ndash

Silty Clay

Loa

m

Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180

ECe (dSm) 0 1 2

0 30 60 90

120

14 16 18

3 4

Dep

th (cm) Results


0 2 4 6 Soil ‐ Spring 2013







180


Results 2013 2014



2 6 119 6 93

3 6 83 7 44

4 6 81 6 54

5 5 98 5 92

6 6 104 6 82

7 6 84 6 78




























Page -1-























of 3





JACK ALVAREZ

Page 3 of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits














































Very truly yours

JOHN HERRICK

shy

+ bull


Alfalfa Culture




Stockton CA

December 16 2016



























Results 2013 2014




2 150 141 074 3 130 98 088 5

3 140 14 057 21 140 12 040 18

4 150 95 047 3 120 107 057 2

5 130 36 178 25 130 41 193 26

6 120 81 085 6 130 98 087 5

7 140 31 036 7 150 38 049 8



Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180



Soil ‐ Fall 2013




Soil ‐ Fall 2014





Site

3 ndash

Silty Clay

Loa

m



th (cm)

Soil ‐ Fall 2013




Soil ‐ Fall 2014






Soil ‐ Fall 2013




Soil ‐ Fall 2014


Site

2 ndash

Silty Clay

Loa

m

Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180

ECe (dSm) 0 1 2

0 30 60 90

120

14 16 18

3 4

Dep

th (cm) Results


0 2 4 6 Soil ‐ Spring 2013







180


Results 2013 2014



2 6 119 6 93

3 6 83 7 44

4 6 81 6 54

5 5 98 5 92

6 6 104 6 82

7 6 84 6 78




























Page -1-























Page 2 of 3





JACK ALVAREZ

of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits





































Very truly yours

JOHN HERRICK

shy

+ bull


Alfalfa Culture




Stockton CA

December 16 2016



























Results 2013 2014




2 150 141 074 3 130 98 088 5

3 140 14 057 21 140 12 040 18

4 150 95 047 3 120 107 057 2

5 130 36 178 25 130 41 193 26

6 120 81 085 6 130 98 087 5

7 140 31 036 7 150 38 049 8



Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180



Soil ‐ Fall 2013




Soil ‐ Fall 2014





Site

3 ndash

Silty Clay

Loa

m



th (cm)

Soil ‐ Fall 2013




Soil ‐ Fall 2014






Soil ‐ Fall 2013




Soil ‐ Fall 2014


Site

2 ndash

Silty Clay

Loa

m

Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180

ECe (dSm) 0 1 2

0 30 60 90

120

14 16 18

3 4

Dep

th (cm) Results


0 2 4 6 Soil ‐ Spring 2013







180


Results 2013 2014



2 6 119 6 93

3 6 83 7 44

4 6 81 6 54

5 5 98 5 92

6 6 104 6 82

7 6 84 6 78




























Page -1-























Page 2 of 3





JACK ALVAREZ

Page 3 of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits


Alfalfa Culture




Stockton CA

December 16 2016



























Results 2013 2014




2 150 141 074 3 130 98 088 5

3 140 14 057 21 140 12 040 18

4 150 95 047 3 120 107 057 2

5 130 36 178 25 130 41 193 26

6 120 81 085 6 130 98 087 5

7 140 31 036 7 150 38 049 8



Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180



Soil ‐ Fall 2013




Soil ‐ Fall 2014





Site

3 ndash

Silty Clay

Loa

m



th (cm)

Soil ‐ Fall 2013




Soil ‐ Fall 2014






Soil ‐ Fall 2013




Soil ‐ Fall 2014


Site

2 ndash

Silty Clay

Loa

m

Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180

ECe (dSm) 0 1 2

0 30 60 90

120

14 16 18

3 4

Dep

th (cm) Results


0 2 4 6 Soil ‐ Spring 2013







180


Results 2013 2014



2 6 119 6 93

3 6 83 7 44

4 6 81 6 54

5 5 98 5 92

6 6 104 6 82

7 6 84 6 78




























Page -1-























Page 2 of 3





JACK ALVAREZ

Page 3 of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits



























Results 2013 2014




2 150 141 074 3 130 98 088 5

3 140 14 057 21 140 12 040 18

4 150 95 047 3 120 107 057 2

5 130 36 178 25 130 41 193 26

6 120 81 085 6 130 98 087 5

7 140 31 036 7 150 38 049 8



Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180



Soil ‐ Fall 2013




Soil ‐ Fall 2014





Site

3 ndash

Silty Clay

Loa

m



th (cm)

Soil ‐ Fall 2013




Soil ‐ Fall 2014






Soil ‐ Fall 2013




Soil ‐ Fall 2014


Site

2 ndash

Silty Clay

Loa

m

Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180

ECe (dSm) 0 1 2

0 30 60 90

120

14 16 18

3 4

Dep

th (cm) Results


0 2 4 6 Soil ‐ Spring 2013







180


Results 2013 2014



2 6 119 6 93

3 6 83 7 44

4 6 81 6 54

5 5 98 5 92

6 6 104 6 82

7 6 84 6 78




























Page -1-























Page 2 of 3





JACK ALVAREZ

Page 3 of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits


Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180



Soil ‐ Fall 2013




Soil ‐ Fall 2014





Site

3 ndash

Silty Clay

Loa

m



th (cm)

Soil ‐ Fall 2013




Soil ‐ Fall 2014






Soil ‐ Fall 2013




Soil ‐ Fall 2014


Site

2 ndash

Silty Clay

Loa

m

Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180

ECe (dSm) 0 1 2

0 30 60 90

120

14 16 18

3 4

Dep

th (cm) Results


0 2 4 6 Soil ‐ Spring 2013







180


Results 2013 2014



2 6 119 6 93

3 6 83 7 44

4 6 81 6 54

5 5 98 5 92

6 6 104 6 82

7 6 84 6 78




























Page -1-























Page 2 of 3





JACK ALVAREZ

Page 3 of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits

Site

3 ndash

Silty Clay

Loa

m



th (cm)

Soil ‐ Fall 2013




Soil ‐ Fall 2014






Soil ‐ Fall 2013




Soil ‐ Fall 2014


Site

2 ndash

Silty Clay

Loa

m

Dep

th (cm)

ECe (dSm) 0 2 4 6 8 10 12

0

30

60

90

120

150

180

ECe (dSm) 0 1 2

0 30 60 90

120

14 16 18

3 4

Dep

th (cm) Results


0 2 4 6 Soil ‐ Spring 2013







180


Results 2013 2014



2 6 119 6 93

3 6 83 7 44

4 6 81 6 54

5 5 98 5 92

6 6 104 6 82

7 6 84 6 78




























Page -1-























Page 2 of 3





JACK ALVAREZ

Page 3 of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits

Dep

th (cm) Results


0 2 4 6 Soil ‐ Spring 2013







180


Results 2013 2014



2 6 119 6 93

3 6 83 7 44

4 6 81 6 54

5 5 98 5 92

6 6 104 6 82

7 6 84 6 78




























Page -1-























Page 2 of 3





JACK ALVAREZ

Page 3 of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits

Results 2013 2014



2 6 119 6 93

3 6 83 7 44

4 6 81 6 54

5 5 98 5 92

6 6 104 6 82

7 6 84 6 78




























Page -1-























Page 2 of 3





JACK ALVAREZ

Page 3 of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits




























Page -1-























Page 2 of 3





JACK ALVAREZ

Page 3 of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits























Page 2 of 3





JACK ALVAREZ

Page 3 of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits





JACK ALVAREZ

Page 3 of 3



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits



Executive summary





1 | P a g e








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits








2 | P a g e






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits






3 | P a g e




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits




Methods


4 | P a g e









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits









5 | P a g e





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits





6 | P a g e





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits





2013 2014




2 Old River 05-10 074 16-46 312 07-12 088 11-50 355


4 Middle River 03-08 047 12-36 202 05-07 057 20-32 273

5 Paradise Cut 03-28 178 54-135 802 16-31 193 72-191 914

6 Grant Line Canal 06-11 085 25-47 381 06-11 087 26-56 399

7 North Canal 03-04 036 11-20 142 04-06 049 18-30 232





1

2

3

4

5

6

7

117

177

198

197

168

155

185

107

96

37

57

52

36

30

775

723

192

361

299

187

121

148

153

208

192

177

182

102

78

106

23

62

48

30

35

495

765

76

522

253

145

126

117

132

232

218

157

162

135

110

122

30

51

60

28

27

764

923

132

334

335

139

111

183

117

200

212

177

163

155

70

143

27

57

44

36

36

450

1087

112

379

234

183

156

7 | P a g e




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits




8 | P a g e


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits


9 | P a g e

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits

A

C

E

G

D

B

F


10 | P a g e




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits




1 435 677 579 741 528

2 753 886 807 718 660

3 107 098 071 096 No data

4 467 510 469 596 515

5 227 240 277 313 190

6 557 570 556 689 477

7 172 175 148 251 No data




1 295 478 397 458 330

2 551 709 630 435 422

3 44 37 32 36 No data

4 240 328 334 378 346

5 113 126 138 154 90

6 262 342 339 402 246

7 45 65 54 77 No data



11 | P a g e




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits




2013 2014



1 100 112 848 3 2 120 98 602 3 2

2 150 141 1142 3 1 130 98 580 5 3

3 140 14 50 21 23 140 12 49 18 19

4 150 95 651 3 2 120 107 662 2 2

5 130 36 206 25 20 130 41 207 26 25

6 120 81 530 6 5 130 98 570 5 4

7 140 31 117 7 7 150 38 105 8 14

12 | P a g e



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits



2013 2014



1 6 82 187 6 56 127

2 6 119 271 6 93 212

3 6 83 189 7 44 100

4 6 81 184 6 54 123

5 5 98 223 5 92 209

6 6 104 237 6 82 187

7 6 84 191 6 78 177

Summary



13 | P a g e


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits


Acknowledgements


References










14 | P a g e












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits












15 | P a g e


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits


16 | P a g e

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits

________________________________________







1


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits


DWR AND USBR




I Background



SDWA-2









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits









2






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits






1) Dilution Needs


3








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits








4







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits







5







6






7








8

10_sdwa_comment







Hildebrand Exhibits







6






7








8

10_sdwa_comment







Hildebrand Exhibits






7








8

10_sdwa_comment







Hildebrand Exhibits








8

10_sdwa_comment







Hildebrand Exhibits

10_sdwa_comment







Hildebrand Exhibits

New SOUTH DELTA WATERAGENCY · 2017. 5. 18. · According to plant and soil science, plant health...

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Transcript of New SOUTH DELTA WATERAGENCY · 2017. 5. 18. · According to plant and soil science, plant health...