Irrigation Districts Agree to Study Tuolumne River Fish Passage

Modesto Irrigation District and Turlock Irrigation District, owners and operators of the La Grange and Don Pedro hydroelectric projects on the Tuolumne River, agreed November 21 to conduct studies related to passing salmon and steelhead past both projects. The Districts filed with the Federal Energy Regulatory Commission (FERC) an “Updated Study Plan” for the licensing of the La Grange Project. The filing contains a draft “Fish Passage Assessment” Study Plan that proposes to evaluate the suitability of habitat in the Tuolumne River upstream of Don Pedro Reservoir for reintroduction of salmon and steelhead. The Assessment also proposes to evaluate conceptual level alternatives and costs for moving fish past La Grange and Don Pedro reservoirs.

The decision by the Districts will, once approved by FERC, represent the first instance in which fish passage is evaluated in a FERC licensing proceeding in California’s Central Valley. It is an outcome for which CSPA has tirelessly advocated on the Tuolumne for three years and for which CSPA has advocated more generally in the Valley for over seven years. The decision by the Districts is thus at once a landmark in hydropower licensing generally and in CSPA’s hydropower advocacy in particular.  The decision by the Districts comes after a series of events, including a La Grange licensing meeting on October 6 during which CSPA, National Marine Fisheries Service and others advocated that the Districts conduct fish passage studies.

CSPA is convinced that Central Valley salmon and steelhead cannot survive on the Valley floor alone, downstream of the rim dams that block passage on every major Valley river. However, the suitability of any candidate area for upstream reintroduction needs to be evaluated in each particular location. We look forward to working with the Districts to evaluate the suitability of habitat on the upper Tuolumne and to evaluate opportunities for getting salmon and steelhead to that habitat.

Districts’ Updated Study Plan and Notes from October 6 licensing meeting

Conservation Groups’ comments

Posted in Chris Shutes, Hydroelectric (FERC) | Comments Off

CSPA Dismisses Protest against North San Joaquin Water Conservation District

CSPA has dismissed its 2009 water rights protest against the North San Joaquin Water Conservation District. CSPA’s dismissal will allow the District to use time-restricted funding to complete a groundwater recharge project. North San Joaquin will report annually to CSPA regarding its projects and its efforts to bring its groundwater into balance.

North San Joaquin petitioned in 2007 for more time to use all the water it was allowed to use under a 1950’s era water rights permit. When the petition was noticed by the State Water Board in 2009, CSPA protested on four major grounds: the District had no project planned to use more water, had no money for a project, had performed no environmental review, and perhaps most importantly had no demonstrable intent to bring its overdrafted groundwater into balance. For several years after the protest was filed, things deteriorated at the District: its members voted down a charge on groundwater pumping to pay for infrastructure, and its Board became very dysfunctional. However, since 2012, the District has changed direction. It has partnered with San Joaquin County, it has defined several projects, it has secured funding, and it has completed environmental review for its first major project.

The recently passed legislation to regulate groundwater, while requiring less reporting than CSPA had advocated for, provides a new backstop that over the long term will help protect against worsening groundwater levels. More positively, many areas in the District have reduced demand and improved previously overdrafted conditions, and both the District and the County appear serious about groundwater sustainability. The relatively small amount of water available under an extended permit will allow North San Joaquin and its partner San Joaquin County to develop pilot projects that demonstrate their ability to stabilize water use.

14 09 29 Agreement to Resolve Water Right Protest

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San Francisco Can Do Better Than Just Say No to Tuolumne Flow

Since 2009, representatives of the City and County of San Francisco have consistently advocated against flow increases in the lower Tuolumne River. In proceedings before the Federal Energy Regulatory Commission and the State Water Board, San Francisco’s advocates have argued that increased flow will cause economic disaster during dry year sequences. The general strategy of the City’s attorneys, staff and consultants has been to make a bunch of assumptions about dry year water supply and demand and rationing, and then to have a few experts describe in vivid detail what would happen if those assumptions were true. Then they argue that since increased flow can’t work in droughts, there’s just nothing to do.

On July 29, 2014, San Francisco’s City Attorney sent a letter to staff at the State Water Board with a new version of the same tired arguments. The immediate issue was how the State Water Board will evaluate impacts to the City in an environmental analysis of changes to flow in tributaries of the San Joaquin River, including the Tuolumne. A copy of the letter was filed with FERC.

On October 8, 2014, ten conservation groups who’ve been working in FERC proceedings on the Tuolumne River, including CSPA, filed a response to the City’s letter with both the State Water Board and with FERC. The conservation groups’ response provides background about the City’s advocacy over the last five years and makes numerous suggestions about different ways the City might comply with increased flow requirements or mitigate their impacts to the City’s water supply and economy. These include creating different flow requirements during multiple dry years and expanding efforts (some of which are already underway) to secure alternative supplies if Tuolumne River supplies run short.

One of the few positive things about the current drought is that it has shown that people, especially in the Bay Area, value water conservation and are willing to work at it. Bay Area water agencies are talking to each other about sharing resources and infrastructure, particularly during drought situations. Agricultural demand reduction by other users of Tuolumne River water is also going to have to be part of the solution.

The San Francisco Board of Supervisors passed a resolution on July 22, 2014 stating that the “… San Francisco Bay-Delta Estuary helps to power [the Bay Area’s] economic engines, is the globally recognized symbol of our region, and its health reflects on our region’s capacities, values and vibrancy . . . .” San Francisco needs to line up its water supply policies with its values. The most progressive City in the world can and must do better than just say no.

Conservation Groups’ October 8, 2014 Response to City and County of San Francisco

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CSPA Works to Make Delta Flow Work

The 2010 Delta Flow Criteria Report announced findings by the State Water Board that additional flow into and out of the Delta was needed to restore fisheries. The Report stated: “In order to preserve the attributes of a natural variable system to which native fish species are adapted, many of the criteria developed by the State Water Board are crafted as percentages of natural or unimpaired flows.”

CSPA strongly supports the percent-of-unimpaired approach to developing Delta flow requirements. However, figuring out how to actually implement this approach takes a lot of work. The State Board has not done much to advance understanding. Resource agencies have not consistently advocated for it. Other environmental and fishing groups have supported it as a principle, but have made little apparent effort to demonstrate its feasibility or evaluate the reservoir operations that it would require. And, of course, many irrigation districts and water agencies have hired talented modelers with the general intent of making a percent-of-unimpaired approach appear unreasonable.

License applicants in relicensings of three key Central Valley hydroelectric projects (Merced River Project, Don Pedro Project on the Tuolumne, and Yuba River Development Project) have developed daily operations models that allow careful analysis of how a percent-of-unimpaired approach could be implemented. CSPA’s hydropower advocate, with help from several engineers, has used these models to evaluate two of the systems: Merced River and Yuba River. In July, 2014 we posted the product of some of that work for the Merced River (“CSPA Proposes High Spring Flows on Merced River”). On September 24, 2014, CSPA made a presentation in the Yuba River Development relicensing discussing how conceptually a percent-of-unimpaired approach might be overlaid onto flows developed in the 2008 Yuba Accord to improve instream flow benefits both in the Yuba River and in the Delta downstream. Over the coming year, CSPA will be working on a similar analysis for the Tuolumne River.

CSPA flow presentation Yuba River 092414

Posted in Chris Shutes, Hydroelectric (FERC), State Board Bay-Delta Standards | Comments Off

Media Advisory: Salmon Fishermen to Oppose Prop. 1

San Francisco – Bay Area fishermen announced today they will oppose Proposition 1, the State Water Bond, at a San Francisco Bay news conference on Friday, Oct. 3. “Prop. 1 is one more shovel of dirt on the grave of our salmon, crab and other Pacific fisheries,” said Larry Collins, of the San Francisco Crab Boat Association. “Building more dams to hold water we don’t have is misplaced spending and harms the businesses, families and communities that depend upon our salmon, crab and other fisheries.”

WHAT: Bay Area Fishermen to Oppose Prop. 1 – Harms Salmon Fisheries

WHEN: Friday, October 3, 2014 10:30 am

WHO: Larry Collins, San Francisco Crab Boat Association; Mike Hudson, Small Boat Commercial Salmon Fishermen’s Association; Zeke Grader, Pacific Coast Federation of Fishermen’s Associations

WHERE: Pier 45, Shed D5, San Francisco Bay

See full media advisory here. For more information, please visit www.noonprop1.org

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CSPA Settles Lawsuit Against City of Watsonville

On 30 September 2014, CSPA settled a Clean Water Act lawsuit against the City of Watsonville for violations of the California General Industrial Stormwater Permit. The City operates a 1.6-acre Material Recovery Facility, a 5.8-acre Corporation Yard and a 100-acre landfill in Watsonville, California. The lawsuit alleged that the facilities discharged polluted stormwater into Watsonville Slough, Gallighan Slough, the Pajaro River and ultimately Monterey Bay.

The settlement agreement obligates the City to comply fully with the Clean Water Act, develop and implement a suite of Best Management Practices and structural improvements, conduct more frequent and comprehensive monitoring and prepare an adequate Stormwater Pollution Prevention Plan. The agreement incorporates provisions that allow CSPA to return to court for enforcement if pollutant benchmarks continue to be exceeded.

As mitigation for past violations, Watsonville agreed to send $27,500 to the Rose Foundation for Communities and the Environment to fund environmental projects to improve water quality in local watersheds. They also agreed to reimburse CSPA’s costs of bringing suit. The Law Offices of Andrew Packard represented CSPA in this matter.

Consent Agreement

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CSPA Settles Lawsuit Against Sacramento Auto Dismantler

On 27 September 2014, CSPA settled a Clean Water Act lawsuit against Pick and Pull Auto Dismantlers, Pick and Pull Auto Dismantling, Inc., and Norprop, Inc. (collectively, PNP. for violations of the federal Clean Water Act and California’s General Industrial Stormwater Permit. PNP operates an automobile recycling facility in Sacramento, California. The lawsuit alleged that the facility discharged polluted stormwater into the Sacramento storm sewer system and local surface waters, including Elder and Morrison Creeks, which are tributaries to the Sacramento River.

The settlement agreement obligates PNP to comply fully with the Clean Water Act, develop and implement a suite of Best Management Practices and structural improvements, conduct more frequent and comprehensive monitoring and prepare an adequate Stormwater Pollution Prevention Plan. The agreement incorporates provisions that allow CSPA to return to court for enforcement if pollutant benchmarks continue to be exceeded.

As mitigation for past violations, PNP agreed to send $35,000 to the Rose Foundation for Communities and the Environment to fund environmental projects to improve water quality in local watersheds. They also agreed to reimburse CSPA’s costs of bringing suit. Lawyers for Clean Water represented CSPA in this matter.

Settlement Agreement

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CSPA Settles Lawsuit Against Rocklin Auto Dismantler

On 26 September 2014, CSPA settled a Clean Water Act lawsuit against Pick and Pull Auto Dismantlers, Pick and Pull Auto Dismantling, Inc., and Norprop, Inc. (collectively, PNP. for violations of the federal Clean Water Act and California’s General Industrial Stormwater Permit. PNP operates an automobile recycling facility in Lincoln, California. The lawsuit alleged that the facility discharged polluted stormwater into the City of Rocklin’s storm sewer system and local surface waters including Antelope Creek, which are tributaries to the Sacramento River.

The settlement agreement obligates PNP to comply fully with the Clean Water Act, develop and implement a suite of Best Management Practices and structural improvements, conduct more frequent and comprehensive monitoring and prepare an adequate Stormwater Pollution Prevention Plan. The agreement incorporates provisions that allow CSPA to return to court for enforcement if pollutant benchmarks continue to be exceeded.

As mitigation for past violations, PNP agreed to send $35,000 to the Rose Foundation for Communities and the Environment to fund environmental projects to improve water quality in local watersheds. They also agreed to reimburse CSPA’s costs of bringing suit. Lawyers for Clean Water represented CSPA in this matter.

Settlement Agreement

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CSPA Submits Comments and Testifies at State Board Workshop on Delta Water Availability

On 24 September 2014, CSPA testified at a State Water Resource Control Board (State Board) workshop regarding a proposed order on Central and Southern Delta Water Availability and Use. CSPA had previously submitted comments on 15 September.

The stated purpose of the workshop was to receive comments and discuss the process the State Board should use to address recent allegations by the Department of Water Resources (DWR) and U.S. Bureau of Reclamation (USBR) that Delta water users were stealing project water. Attached to the hearing notice was a draft order requiring riparian and pre-1914 appropriative water right claimants within the Delta to provide specific information regarding the type of water right and monthly amounts of water diverted under each claim.

CSPA joined South and Central Delta Water Agencies, San Joaquin County and other representatives of Delta landowners in recommending the State Board conduct a formal evidentiary hearing, with cross-examination and rebuttal. Baring that, CSPA and Delta interests recommended that all parties agree to refer the matter to court to address the factual and legal issues.

CSPA characterized the process as a witch hunt and compared the State Board to a store manager, facing allegations of missing inventory, who didn’t know how much inventory was delivered to the store or how much or by what means inventory was removed and who proposed to address the problem by installing a checkout counter for a small subset of customers: in this case, Delta farmers. CSPA pointed out that: actual Delta outflow, natural inflow, accretions and channel losses in both the tributaries and Delta are all calculated “guestimates;” the projects had “commingled riparian and stored water and that “abandoned water” in the Delta was subject to public trust requirements and the water rights seniority system.

CSPA suggested that if the State Board desired to pursue allegations that Delta farmers were illegally taking water belonging to the state and federal projects, it needs to first determine whether the water DWR and USBR claim is being taken actually reaches the Delta and whether the projects have legal rights to it. It must quantify the volume and source of commingled water in both upstream waters and the Delta Pool and then sort out the legal rights to that water.

The State Board was clearly troubled by the testimony and made no decision. Earlier, the Board had clarified that CSPA’s formal 13 August complaint alleging that DWR and USBR had been illegally exporting water and petition to adjudicate Central Valley waters would be considered separately.

CSPA Comments   South Delta Water Agency Comments   Central Delta Water Agency Comments

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CSPA Submits Comments and Testifies on State Board Hearing on Order Denying Petitions for Reconsideration of Emergency Orders

On 24 September 2014, CSPA testified at the State Water Resource Control Board’s (State Board) hearing on the draft Order denying petitions for reconsideration and addressing objections regarding the Temporary Urgency Change Petitions (TUCP) for operation of the State Water Project and Central Valley Project. CSPA, CWIN and AquAlliance had submitted comments on the proposed Order on 16 September.

Between 31 January and 2 May, the State Board issued eight TUCP orders modifying and relaxing water quality and flow standards for the Delta. CSPA and a number of others filed formal protests of the emergency orders and CSPA and five other parties filed Petitions for Reconsideration.

CSPA pointed out that the relaxed standards and reduced outflows had a catastrophic impact to listed species and in-Delta beneficial uses and that export pumping should have been curtailed before Delta water quality and flow standards established for drought conditions were discarded. CSPA characterized the TUOP process as an egregious backroom violation of due process and urged the State Board to establish an open public process for any subsequent emergency actions.

Despite almost uniform criticism of the order by environmental and fishing groups and Delta and north-state water agencies, the State Board adopted the order with few changes.

CSPA Comments on Draft Order

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CSPA Settles Lawsuit Against Santa Cruz Concrete Facility

On 24 September 2014, CSPA settled a Clean Water Act lawsuit against Las Animas Concrete & Building Supply for violations of the California General Industrial Stormwater Permit. Las Animas operates a 2.4-acre concrete production plant in Santa Cruz, California. The lawsuit alleged that the facility discharged polluted stormwater into the San Lorenzo River.

The settlement agreement obligates Las Animas to comply fully with the Clean Water Act, develop and implement a suite of Best Management Practices and structural improvements, conduct more frequent and comprehensive monitoring and prepare an adequate Stormwater Pollution Prevention Plan. The agreement incorporates provisions that allow CSPA to return to court for enforcement if pollutant benchmarks continue to be exceeded.

As mitigation for past violations, Las Animas agreed to send $15,000 to the Rose Foundation for Communities and the Environment to fund environmental projects to improve water quality in local watersheds. They also agreed to reimburse CSPA’s costs of bringing suit. The Law Offices of Andrew Packard represented CSPA in this matter.

Settlement Agreement

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CSPA Settles Lawsuit Against Lincoln Ready-Mix Plant

On 24 September 2014, CSPA settled a Clean Water Act lawsuit against Syar Concrete, LLC and Syar Industries, Inc. for violations of the Clean Water Act and California’s General Industrial Stormwater Permit. Syar operates a readymix concrete batch plant facility in Lincoln, California. The lawsuit alleged that the facility discharged polluted stormwater into Markham Ravine, which flows to the Sacramento River.

The settlement agreement obligates Syar to comply fully with the Clean Water Act, develop and implement a suite of Best Management Practices and structural improvements, conduct more frequent and comprehensive monitoring and prepare an adequate Stormwater Pollution Prevention Plan. The agreement incorporates provisions that allow CSPA to return to court for enforcement if pollutant benchmarks continue to be exceeded.

As mitigation for past violations, Syar agreed to send $30,000 to the Rose Foundation for Communities and the Environment to fund environmental projects to improve water quality in local watersheds. They also agreed to reimburse CSPA’s costs of bringing suit. Lawyers for Clean Water represented CSPA in this matter.

Settlement Agreement

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CSPA Files Comments and Objection to June Lakes TUCP Petition and Order

On 19 September 2014, CSPA submitted comments and a formal objection to a temporary urgency change petition and order regarding a change in required minimum flows past the June Lake Public Utility District’s (JLPUD) Fern Creek diversion facility. CSPA pointed out that JLPUD’s temporary change petition was identical to he District’s previous petition for permanent change to cut flows to one-eighth of requirements agreed to in 1998. The JLPUD provided no evidence that the proposed flow reduction is protective of Brook trout and other fishery resources in Fern Creek.

CSPA Comments and Objection

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CSPA, Coalition Submits Amicus to Supreme Court in Scott River Case

On 19 September 2014, CSPA, Karuk Tribe, California Coastkeeper Alliance, Northcoast Environmental Center, Friends of the Eel River and Clean Water Action submitted a Amici Curiae letter to the California Supreme Court regarding the appeal of Siskiyou County to the decision by the Sacramento Superior Court that the public trust doctrine protects the Scott River from harm caused by overwithdrawal of the river’s interconnected groundwater. Excessive groundwater pumping has literally dewatered significant reaches of the Scott River. The Coalition letter says that the Scott River case raises issues of environmental and legal significance as great as those in the Court’s Mono Lake Decision.

Scott River Amicus

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CSPA Settles Lawsuit Against Sacramento Concrete Facility

On 14 September 2014, CSPA settled a Clean Water Act lawsuit against Jensen Precast for violations of the California General Industrial Stormwater Permit. Jensen Precast operates a concrete product manufacturing and fabrication facility in Sacramento, California. The lawsuit alleged that the facility discharged polluted stormwater into Magpie Creek, which flows to Steelhead Creek, which discharges to the Sacramento River.

The settlement agreement obligates Jensen Precast to comply fully with the Clean Water Act, develop and implement a suite of Best Management Practices and structural improvements, conduct more frequent and comprehensive monitoring and prepare an adequate Stormwater Pollution Prevention Plan. The agreement incorporates provisions that allow CSPA to return to court for enforcement if pollutant benchmarks continue to be exceeded.

As mitigation for past violations, Jensen Precast agreed to send $37,500 to the Rose Foundation for Communities and the Environment to fund environmental projects to improve water quality in local watersheds. They also agreed to reimburse CSPA’s costs of bringing suit. Lawyers for Clean Water represented CSPA in this matter.

Settlement Agreement

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CSPA, Coalition Issue Comments on BDCP Scoping Process

On 10 September 2014, CSPA, Friends of the River, the Environmental Water Caucus and California Water Impact Network sent a letter regarding the scoping process for recirculated Bay Delta Conservation Plan (BDCP) documents. BDCP announced that it would shortly announce the scope of documents to be recirculated in the near future. The Coalition pointed out that a new or subsequent BDCP EIR/EIS – not just a supplement – will be required by NEPA, CEQA, the Endangered Species Act, NCCP Planning Act and Delta Reform Act because of the necessity of making more than minor additions or changes. Consequently, BDCP must begin a new scoping process.

BDCP Scoping Letter

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CSPA, Coalition Submits Information to Regional Board on Grassland Bypass Project

On 8 September 2014, CSPA and a Coalition of environmental and fishing groups, responding to a request by Central Valley Regional Board Chair Karl Longley, provided information on the estimated reduction in discharges of drainage, salt, selenium and boron from permanent land retirement of the impaired irrigated lands on the Westside of the San Joaquin River basin. The request arose during the coalition’s presentation at an 8 August Regional Board workshop on draft wastes discharge requirements for the Grassland’s Bypass Project. The Coalition also provided additional comments regarding the need to issue a permit for the Panoche Demonstration Treatment Plant.

Coalition Letter

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CSPA, Coalition Submit Comments on BDCP Reasonable Range of Alternatives

On 4 September 2014, CSPA, Friends of the River, the Environmental Water Caucus and California Water Impact Network sent a letter regarding consideration of a reasonable range of alternative in any recirculated draft Plan, EIR/EIS and Implementing Agreement for the Bay Delta Conservation Plan (BDCP). In response to thousands of highly critical comments, BDCP announced that it would go back to the drawing boards and revise and recirculate new documents. The Coalition pointed out that both the California Environmental Quality Act and National Environmental Policy Act require consideration of a reasonable range of alternatives and urged BDCP to incorporate the Coalition’s Responsible Exports Plan in any subsequent evaluation.

Coalition Letter on Reasonable Alternatives

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CSPA Releases 14-Point Analysis/Opposition to Water Bond

On 3 September 2014, the California Sportfishing Protection Alliance (CSPA) released a 14-Point Analysis and Statement of Opposition to the Proposition 1 Water Bond that is on the 4 November 2014 ballot. The $7.5 billion Bond includes $2.7 billion for new dams and is a serious threat to the Delta and Central Valley rivers and fisheries.

Among numerous reasons the water bond is bad for California is that Proposition 1 undermines: the public trust doctrine by purchasing water the public already owns, at inflated prices, to protect the public’s rivers and environment; the principle of beneficiary pays by subsidizing projects that benefit special interests and the core principle that projects should be responsible for mitigating their adverse impacts.

Furthermore, Proposition 1: paves the way for a new era of big dam building; is a pork-filled barrel of special interest subsidies, including BDCP; provides little near-term drought relief; eliminates public oversight; crowds out other critically needed investments in roads, schools and public health & safety; is fiscally irresponsible and sabotages efforts to meaningfully address California’s continuing water crisis.

CSPA Executive Director Bill Jennings observed, “Proposition 1 is a poster-child of why California is in a water crisis; it enriches water speculators but accomplishes little in addressing the drought, solving California’s long-term water needs, reducing reliance on the Delta or protecting our rivers and fisheries. When the pubic focuses a critical eye on Prop. 1, they’ll realize that it’s just another expensive pork-filled gift basket to special interests.”

CSPA joins the Pacific Coast Federation of Fishermen’s Associations, San Francisco Crab Boat Association, Restore the Delta, Center for Biological Diversity, California Water Impact Network, Food & Water Watch, Southern California Watershed Alliance, South Delta Water Agency, Central Delta Water Agency, Concerned Citizens Coalition of Stockton, Winnemem Wintu Tribe, Small Boat Commercial Salmon Fisherman’s Association and numerous other fishing, environmental, water and civic organizations in opposing Proposition 1. The No on Prop 1 website is still under construction but can be found at www.noonprop1.org.

CSPA 14-Point Analysis, Opposition to Prop. 1   CSPA Press Release

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CSPA, Coalition Request Extension of Review Period for Statewide Pest EIR

On 2 September 2014, CSPA and 14 other environmental and health organizations sent a letter to the California Department of Food and Agriculture requesting a 90-day time extension of the public review period for the Statewide Plant Pest Prevention Programmatic Environmental Impact Report. The letter pointed out that the minimum 45-day review period was insufficient time to analyze and prepare responsive comments on the more than 3,500 pages of text plus extensive data files.

Coalition Request For Time Extension

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