April 15, 2022
Here is a summary of our comments:
1) We find the climate change analysis used as the basis for the GSP is not sufficiently robust to reflect currently anticipated climate change conditions for the region. The analysis does not reflect current science. For this reason, we suggest DWR provide more direction in this area for future GSP updates.
2) We believe a review of the GSP utilizing Article 6, Section 355.4 finds the plan deficient in several important areas. Our findings are listed in more detail below. DWR should work with the subbasin GSAs to address the shortcomings described below before approving the GSP.