Harmful Algal Blooms (HAB) data currently are not included in most Stormwater Pollution Prevention Plan construction permits. Historically, analysis for potential for algal blooms in the Delta relies on operational assumptions, including diversion patterns at the north and south Delta intakes, that will be evaluated in the EIR. This comment is related to the scope of DWR’s EIR; please consider submitting this comment through DWR’s CEQA scoping process.