Dec. 20, 2012 Environmental Water Caucus Slams Bay Delta Conservation Plan

Written By: Dan Bacher, December 20, 2012

Nick Di Croce, one of the facilitators for the Environmental Water Caucus, blasted the controversial Bay Delta Conservation Plan (BDCP) to build the peripheral tunnels during a public meeting in Sacramento on November 29.  

In his testimony, Di Croce indicated that most of the environmental organizations that make up the Caucus are opposed to the proposed tunnels or any other peripheral conveyance intended to divert Sacramento River water under or around the Delta. He characterized BDCP as an “impending environmental and financial disaster whose costs and unsettled financing are going to bury the tunnel-oriented project.”  

He said his organization has questioned the U.S. Department of Interior and the California Natural Resources Agency on what the real costs of fixing the Delta are, who is really going to pay for the project, and where the water is going to come from. Their questions were not answered by any of the state and federal officials and private contractors who spoke at the meeting Thursday.  

The Caucus also cited the three major factors that must be a part of any major Delta project. They are: 

(1) A detailed analysis of how much water the Delta needs to be healthy and how much water is really available for export from the Delta; 

(2) A valid cost benefit analysis to determine which projects should be undertaken; and 

(3) A balancing of Public Trust values in order to protect the public’s heritage and the ecosystem services of its streams and estuaries.  

"A recent workshop conducted by the State Water Board has shown that legitimate claims to water flowing into the Bay Delta exceed the available water supply by more than five times in most years – which begs the question of whether there is more water available for BDCP. The refusal of the BDCP project to perform a legitimate cost benefit analysis is understandable; it will undoubtedly show the project is not to be able to pay for itself without inventing specious billions of dollars of guaranteed assurances," according to Di Croce.  

"Similarly, not balancing public trust values is also understandable; that would show that the economic value of the services provided to the state and public by healthy, flowing rivers and estuaries far exceeds the value of water exports to a select few business enterprises south of the Delta," he said.  

The Caucus recommends that the BDCP discontinue its proposed plan for tunnels and adopt a "more sustainable and less expensive plan" that has been presented to the Delta Stewardship Council by the Caucus.  

"Instead of the $14 billion tunnels, which will be buried before we get a chance to know if BDCP can work, the Environmental Water Caucus plan includes a more aggressive water conservation and efficiency program to more than make up for reduced exports, the elimination of irrigation water for impaired farmlands in the San Joaquin Valley, the installation of improved fish screens in the South Delta, the continuation of the Biological Opinions’ pumping restrictions that have been helpful to the fisheries, the reinforcing of key levees in the Delta, and a series of related actions that will improve the ecology of the Delta and provide a higher degree of water supply reliability for farmers and urbans," Di Croce concluded.  

After he spoke, Di Croce told me, in reference to the presentations made by state and federal officials and contractors at the meeting, "The charade continues."  

Details of the EWC plan are described at  

Di Croce's comments were the highlight of the meeting during which Deputy Natural Resources Secretary Jerry Meral said that state and federal officials were not yet ready to publish the draft plan that was originally expected this October.  

"We’re not there yet. We simply don’t have yet a proposed project," admitted Meral.  

Meral said the draft would become available in late January or early February, 2013. He said the draft EIR/EIS for the project, when public comment would be solicited, would become available in the Spring of 2013.  

The final BDCP and EIR/EIS will be issued at the "end of 2012," Meral said.  

Much of the meeting focused on the t=response to agency "red flag" comments earlier this year that indicated that the proposed project would hasten the extinction of Central Valley salmon, Delta smelt, longfin smelt and other fish.  

Dr. David Zippin and Jennifer Pierre of ICF International gave a somewhat confusing presentation responding to the comments. At one point, Pierre stated in regard to a question on Delta outflows, "I don't know how to explain the numbers."  

Meral also claimed that the BDCP would conduct a "comprehensive cost-benefits analysis." This analysis will document "potential costs and benefits of BDCP to other water users and to the public at large," he said.  

"The proposed study takes a statewide perspective, and analyzes impacts to various groups whose welfare may be impacted by the Plan," said Meral. "The Cost and benefit components that will be quantified are divided into three broad categories: construction and operating costs of proposed project, impacts to Delta-dependent economic activities, and non-market environmental impacts."  

At a Finance Working Group meeting in the morning, Dr. David Sunding of U.C. Berkeley and the Brattle Group announced that he is prepared to do a new cost-benefit analysis as soon as he has an actual project (an actual water supply) to analyze for benefits. He spent a lot of time talking about methodology, according to Jane Wagner-Tyack, Restore the Delta policy analyst.

Sunding is the analyst who produced an earlier cost-benefit analysis for BDCP finding that the project will benefit the contractors who are paying for it, but only if it results in “regulatory certainty”: guarantees that the fish agencies won’t step in now and then to limit diversions. Dr. Jeff Michael of UOP’s Business Forecasting Center did an analysis without those guarantees and found that the project would cost $2.50 for each dollar of benefit.

“Dr. Sunding must be on the right track this time. Dr. Michael, who was at the November 29 meeting, said that this meeting showed tremendous improvement,’ although he is concerned about calculating benefits out to infinity and using an unrealistically low interest rate for borrowing associated with the project,” said Wagner-Tyack. 

A video recording of the November 29 Public Meeting is available at  

Fishermen, environmentalists, Indian Tribes, family farmers and elected officials from across the political spectrum oppose the peripheral tunnels because their construction would lead to demise of Sacramento River chinook salmon, Central Valley steelhead, striped bass, largemouth bass, Delta smelt, longfin smelt, green and white sturgeon and other fish populations. 

In addition, they criticize the BDCP's proposed conversion of vast tracts of Delta farmland, some of the most fertile on the planet, in order to greenwash the delivery of massive amounts of Delta water to irrigate drainage impaired land on the west side of the San Joaquin Valley.  

Members of the Environmental Water Caucus include AquAlliance, Butte Environmental Council, California Coastkeeper Alliance, California Save Our Streams Council, California Sportfishing Protection Alliance, California Striped Bass Association, California Water Impact Network, Clean Water Action, Desal Response Group, Environmental Justice Coalition for Water, Earth Law Center, Fish Sniffer Magazine, Foothill Conservancy, Friends of the River, Food & Water Watch, Granite Bay Flycasters, Institute for Fisheries Resources, The Karuk Tribe, North Coast Environmental Center, Northern California Council, Federation of Fly Fishers, Pacific Coast Federation of Fishermen's Associations, Restore the Delta, Sacramento River Preservation Trust, Sacramento Valley Environmental Water Caucus, Save the Bay Association, Sierra Club California, Sierra Club, SF Bay Chapter, Sierra Nevada Alliance, Southern California Watershed Alliance, Water for California and Winnemem Wintu Tribe .

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