United States v. State Water Resources Control Board

CourtDistrict Court, E.D. California
DecidedAugust 30, 2023
Docket2:19-cv-00547
StatusUnknown

This text of United States v. State Water Resources Control Board (United States v. State Water Resources Control Board) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. State Water Resources Control Board, (E.D. Cal. 2023).

Opinion

2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 12 UNITED STATES OF AMERICA, No. 2:19-cv-000547-JLT-EPG

13 Plaintiffs, ORDER GRANTING MOTION TO DISMISS INTERGOVERNMENTAL 14 v. IMMUNITY CLAIM; REQUIRING SUPPLEMENTAL BRIEFING 15 STATE WATER RESOURCES CONTROL CONCERNING REMAINING STATE 16 BOARD & STATE WATER RESOURCES LAW CLAIMS CONTROL BOARD CHAIR E. JOAQUIN 17 ESOUIVEL, in his official capacity, (Doc. 17, 60, 61)

18 Defendants. 30 DAY DEADLINE 19 20 I. INTRODUCTION 21 The United States of America, on behalf of the United States Department of the Interior through 22 its Bureau of Reclamation, filed two similar lawsuits, one in Sacramento County Superior Court, the 23 other in this Court, concerning amendments adopted by Defendant State Water Resources Control Board 24 (“State Board” or “the Board”) to the Water Quality Control Plan for the San Francisco 25 Bay/Sacramento-San Joaquin Delta Estuary (“Bay-Delta Plan Amendments,” “Amendments,” or 26 “Amended Plan”)1. (See Docs. 1; 18-6.) The operative First Amended Complaint in this action raised 27

28 1 The Amended Plan itself is reproduced at Doc. 18-3 and is cited hereafter as “AP”. The Amended Plan, along with other public records cited in this decision, are properly the subject of judicial notice for their existence and content, although not 2 §§ 21000 et seq., along with a cause of action based upon the federal constitutional intergovernmental 3 immunity (“IGI”) doctrine. (Doc. 14.) The United States’ state court complaint alleges the same three 4 causes of action under CEQA but omits the IGI claim. (Doc. 18-6.) 5 In July 2019, the State Board moved to dismiss the FAC, arguing the entire case should be 6 dismissed pursuant to various abstention doctrines and that the IGI claim was both unripe and failed to 7 state a claim. (See Doc. 17.) On December 2, 2019, a previously assigned district judge applied 8 Colorado River abstention to stay the state law (CEQA) claims, while allowing the federal IGI claim to 9 proceed. (Doc. 28.) The United States appealed, and the Ninth Circuit reversed, clarifying that imposing 10 a partial Colorado River stay would only be appropriate in very narrow circumstances not applicable in 11 this case and remanding the case to “allow all of the United States’ claims to proceed, subject to regular 12 issues of justiciability.” (Doc. 49.) As mentioned, the ripeness of the IGI claim was raised in the initial 13 motion to dismiss briefing (see Docs. 17, 20, 21), and was the subject of supplemental briefing (Docs. 14 28, 31, 40, 47, 48), but that issue has yet to be addressed. 15 Following the issuance of the mandate on April 19, 2021, the Court stayed the case at the request 16 of the parties for more than ten months to permit settlement discussions to proceed. (See Docs. 51–59.) 17 When it became clear that the case would not resolve, the Court ordered the parties to file another round 18 of supplemental briefs to update the Court on any recent developments bearing on ripeness. (See Docs. 19 52, 53, 59.) Shortly thereafter, on April 13, 2022, the matter was reassigned to the undersigned. (Doc. 20 62.) The supplemental briefing was complete as of April 21, 2022. (Doc. 64.) 21 For the reasons set forth below, the Court finds that the IGI claim as presently articulated is not 22 ripe for judicial review at this time and dismisses that claim. In addition, the Court calls for 23 supplemental concerning the Court’s exercise of jurisdiction over the remaining state law claims. 24 II. BACKGROUND 25 The originally assigned district judge’s summary of the factual background provides a concise 26 foundation for the analysis in this order: 27

28 for the truth of the matters set forth therein. Fed. R. Evid. 201; Lee v. City of Los Angeles, 250 F.3d 668, 688–90 (9th Cir. 2001). The history of regulation and litigation of issues related to the San 2 Francisco Bay/Sacramento-San Joaquin Delta Estuary (“Bay-Delta”) is 3 long, wide, and deep. Without question, the Bay-Delta itself is a critically important natural resource that is both the hub of California’s water supply 4 and a vital estuary and wetland supporting numerous beneficial uses. Central to the present dispute is the fact that the State Water Board holds 5 authority under California’s Porter-Cologne Water Quality Control Act, Cal. Water Code § 13000, et seq., to adopt water quality control plans to 6 protect the waters of California. The Board adopted its original Water 7 Quality Control Plan for the San Francisco Bay/Sacramento-San Joaquin Delta Estuary (“Bay-Delta Plan”) in 1978, and amended that plan in 1991, 8 1995, and 2006. The most recent effort to amend the Bay-Delta Plan began in 2009, and, over a nine-year period, the Board considered various 9 amendments and prepared environmental documentation analyzing the potential environmental impacts of the Bay Delta Plan Amendments under 10 [the California Environmental Quality Act (“CEQA”)]. 11 The Board held numerous publicly noticed meetings and reviewed 12 thousands of comments regarding the proposed Amendments and related drafts of the Substitute Environmental Document (“SED”) prepared in 13 accordance with CEQA. On December 12, 2018, the Board adopted the SED and Amended Plan. 14

15 In general, the Amendments are designed to accomplish several goals relevant to this case. First, they increase the flows required to be left in the 16 three main salmon-bearing tributaries to the San Joaquin River (the Stanislaus, Tuolumne, and Merced Rivers) during critical months 17 (February through June). These flow increases are designed to improve 18 spawning, rearing, and migratory habitat conditions in the Lower San Joaquin River. The Board plans to implement the flow objectives 19 “adaptively,” within broad constraints, to adjust timing and flow patterns to better balance multiple beneficial uses when scientific information 20 indicates doing so is appropriate.

21 Second, the Amendments provide that the Board will include minimum 22 reservoir carryover storage targets or other requirements to ensure that providing the flows to meet the objectives will not have adverse 23 temperature or other impacts on fish and wildlife.

24 Third, the Amendments revise southern Delta salinity objectives for agriculture by adjusting the salinity requirements/restrictions to a slightly 25 higher level, ostensibly to reflect updated scientific knowledge of southern 26 Delta salt levels that reasonably protect agriculture. More specifically, the Amended Plan revises the salinity objective for agricultural beneficial uses 27 by increasing the April through August salinity objective from a mean daily electrical conductivity (“EC”) of 0.7 deciSiemens per meter 28 (“dS/m”) to 1.0 dS/m, resulting in a 1.0 dS/m salinity objective for the Reclamation’s existing [state-issued] water rights [permits] to operate the 2 federal Central Valley Project (“CVP”), including its permits to operate 3 the New Melones Project, a component of the CVP, currently require Reclamation to meet the [pre-]existing salinity objective of 0.7 dS/m at 4 these locations. The Amended Plan proposes to implement the [revised] salinity objective for the interior southern Delta by requiring Reclamation 5 to continue operating to meet the 0.7 dS/m salinity limit at Vernalis as required by its existing water rights. The Amended Plan also proposes to 6 implement the salinity objective through increased inflows provided by 7 application of flow-based (as opposed to salinity-based) objectives for the Lower San Joaquin River. 8 9 (Doc.

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Bluebook (online)
United States v. State Water Resources Control Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-state-water-resources-control-board-caed-2023.