The Environmental Water Caucus, a diverse coalition including conservation, fishing and environmental justice groups and the Karuk and Winnemem Wintu Tribes, on June 11 responded to Governor Jerry Brown's Bay Delta Conservation Plan and its associated Environmental Impact Report with a stinging 250-page critique of BDCP’s inadequacies and multiple failures to conform to state and federal laws.
“The plan is an omelet of distortion and half-truth intended to mislead and deceive," said Bill Jennings, Executive Director of the California Sportfishing Protection Alliance (CSPA).
Barbara Barrigan-Parrilla, Executive Director of Restore the Delta (RTD), characterizes the BDCP as “a construction project masquerading as a habitat conservation plan."
The core of the plan is the construction of two underground twin tunnels 35 miles long and 40 feet in diameter to deliver Sacramento River to corporate agribusiness interests on the west side of the San Joaquin Valley, Southern California water agencies and oil companies conducting fracking and steam injection operations in Kern County.
Among the criticisms detailed in the Caucus’ review are that it is contrary to the Delta Reform Act of 2009, it fails to provide adequate ecological assurances under state and federal endangered species laws, it fails to assure funding for the project, and it fails to analyze reasonable alternatives to the preferred plan for huge tunnels under the Delta. Other points highlighted by the Caucus include:
• Exporting more water out of the Delta was a foregone conclusion for the main proponents of the plan, which are the powerful water districts south of the Delta. BDCP has cherry picked the science to support that objective and has created 40,000 pages of biased analytical findings to support that predetermined goal, trying to hide the real intent in the process.
• Federal and state laws require that a permissible project must contain a solid financing plan – precisely the kind of plan that BDCP lacks. Even after seven years of planning and debate, BDCP fails to spell out who will be responsible for the $50 to $60 billion cost. Tax payers can expect to pick up most of that tab.
• The Bay Delta “Conservation” Plan has little to do with conservation. In an effort to mislead the public, BDCP disingenuously characterizes the eight-lane expressway sized tunnels that will drain the Delta of life sustaining freshwater as a “Conservation Measure."
• Purporting to restore Delta ecosystems and protect its most vulnerable fish species, BDCP would instead further reduce natural Delta flows to San Francisco Bay, helping push listed, vulnerable salmon and resident fish species into oblivion, and officiate at the demise of California’s salmon industry.
• BDCP proffers the snake-oil hypothesis that physical habitat can substitute for water flows, while ignoring the fact that water is aquatic habitat. While BDCP analyzes the tunnels at a specific project level, habitat is only analyzed at a conceptual level. BDCP only promises to restore some acres of habitat somewhere at sometime in the future, if funding can be secured, while ignoring that most habitat restoration efforts in the past have failed to achieve predicted results.
• BDCP will degrade water quality and harm beneficial uses of water in the Delta, along with promoting wasteful and unreasonable uses of water south of the Delta, contrary to numerous state and federal water quality laws and the California Water Code.
• While BDCP trumpets the risks to California’s water supply from massive Delta levee failures due to earthquakes, BDCP lifts not a finger to address these supposed seismic levee issues.
The Environmental Water Caucus proposes an alternative that reduces water exports to a more sustainable level, in order to permit recovery of the Delta while maintaining water supplies for both Delta and south of Delta water users. The plan, the "Responsible Exports (RX) Plan" sets a cap on water exports of 3 million acre feet in all years. (http://www.restorethedelta.org/wp-content/uploads/2013/05/RESPONSIBLE-EXPORTS-PLAN-MAY-2013.pdf
"The RX Plan includes a unique combination of actions that will open the discussion for alternatives to the currently failed policies which continuously attempt to use water as though it were a limitless resource. The RX Plan is about far more than just reduced exports," according to the Environmental Water Caucus. "The uniqueness of this Plan is that while it will reduce the quantity of water exported from the Bay Delta Estuary, in order to protect the health of the Estuary’s habitat and fisheries with increased inflows and outflows, it also contains actions that will reduce the demand for water and increase supplies for exporters south of the Delta in order to compensate for the reduced south-of-Delta exports."
"It is the only extant plan that will modernize existing facilities in the Bay-Delta with improved fish screens at the South Delta, levees reinforced above the PL84-99 standard, andsignificantly increased flows in order to recover habitat and fish stocks, while avoiding the huge infrastructure costs of tunnels under the Delta," the group explained.
The construction of the peripheral tunnels will hasten the extinction of Central Valley Chinook salmon, Delta and longfin smelt, green sturgeon and other fish species, as well as imperiling the salmon and steelhead populations of the Trinity and Klamath rivers. The habitat "restoration" proposed under the plan will take vast tracks of Delta farmland, among the most fertile on the planet, out of production in order to irrigate toxic, drainage impaired land on the west side of the San San Joaquin Valley.
See the detailed Caucus comments at: http://www.ewccalifornia.org/reports/bdcpcomments6-11-2014-2.pdf
The Environmental Water Caucus includes the following organizations and Tribes:
Butte Environmental Council
California Coastkeeper Alliance
California Save Our Streams Council
California Sportfishing Protection Alliance
California Striped Bass Association
California Water Impact Network (C-WIN)
Clean Water Action
Citizens Water Watch
Desal Response Group
Environmental Justice Coalition for Water
Environmental Protection Information Center
Earth Law Center
Fish Sniffer Magazine
Friends of the River
Food & Water Watch
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
Planning & Conservation League
Restore the Delta
Sacramento River Preservation Trust
Sierra Club California
Southern California Watershed Alliance
Winnemem Wintu Tribe
For more information, contact:
Conner Everts, Environmental Water Caucus connere [at] west.net
Bill Jennings, California Sportfishing Protection Alliance deltakeep [at] me.com
Barbara Barrigan-Parrilla, Restore the Delta barbara [at] restorethedelta.org