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Two Gates Project: the Gateway to Extinction?

By Dan Bacher, editor of the FishSniffer

July 29, 2009 -- The Metropolitan Water District (MWD) of southern California and other water agencies have concocted a new scheme supposedly designed to “protect” the endangered Delta smelt – the "Two Gates Fish Protection Demonstration Project." 
 
However, critics of the project consider the project to be a thinly disguised plan to export more water from the California Delta that will result in the extinction of imperiled Central Valley Chinook salmon, Delta smelt, longfin smelt, green sturgeon and other fish populations. The project is being fast-tracked at the same time that the Schwarzenegger administration, Senator Dianne Feinstein, corporate agribusiness and their allies in the State Legislature are pushing to construct a giant peripheral canal approximately the same size and length as the Panama Canal. 
 
MWD, in a June 9 board meeting, described the Two-Gates Fish Protection Project as a “key near-term project that, according to modeling analysis, should assist in reducing entrainment of Delta smelt and other sensitive aquatic species at the state and federal Delta pumping facilities without adversely affecting Chinook salmon, steelhead, sturgeon or Longfin smelt.” 
 
The project would be implemented by the U.S. Bureau of Reclamation’s installation of operable gate structures on Old River and Connection Slough in the central Delta between the cities of Stockton and Antioch. “Hydrodynamic modeling analyses have also indicated that gate operations could improve water quality in the central and south Delta,” MWD contended. 
 
Governor Arnold Schwarzenegger recently said he was committed to fast-tracking the project to provide “relief” to San Joaquin Valley agribusiness while affirming commitment to a “water deal” that includes a peripheral canal and more dams. 
 
“With mandatory water restrictions and crops lying fallow, it is clear that every Californian is suffering from our water shortage - and this project will provide much-needed relief,” claimed Schwarzenegger, during a break between his staged "green energy" photo opportunities and holding press conferences regarding slashing the state budget. “While I remain committed to getting a comprehensive water deal done this year, I will aggressively work with local, state and federal officials toward the speedy approval and completion of the Two Gates project so that California’s bread basket can continue to feed the world.” 
 
In contrast, Bill Jennings, chairman of the California Sportfishing Protection Alliance, after carefully reviewing the draft Biological Assessment and draft Mitigated Negative Declaration for the Two Gates project, is alarmed that this scheme is “another bullet speeding towards the Delta’s heart.” 
 
“The stated purpose is to circumvent the export restrictions in the recent Biological Opinions (BiOp) issued by the U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries Service (NMFS) by preventing Delta smelt from entering the south Delta where they are susceptible to entrainment in the massive export pumps of the state and federal projects,” said Jennings. “The project was hatched in secrecy, but has now been handed to the U.S. Bureau of Reclamation where it is on a breathtaking fast track to construction this fall.” 
 
Jennings said Two Gates is being "merchandised as a scientific experiment" and admittedly seeks answers to a series of hypotheses that need to be verified. These include: do Delta smelt “surf” the tide, can intermittent operation of the gates affect turbidity, will subtle changes in turbidity cause smelt to avoid certain areas? 
 
“Unfortunately, the reality is that the project is an increased water export scheme masquerading as science," stated Jennings. "Suggestions that conveyance be decoupled from the actual scientific experiment and that any positive effects serve to restore smelt abundance have been rejected. The clear intent of the project is to increase water exports over limits imposed by Judge Wanger's Delta smelt decision and the recent BiOp.” 
 
The Recreational Boaters Association of California is also taking aim at the project over concerns that it will impede navigation on the Delta. 
 
“At issue regarding this project is the long standing policy principle of RBOC to keep the navigable waters of California open and accessible to recreational boating,” stated Dave Breninger, RBOC President. “In this instance, this appears to have not been taken fully into consideration by Cal-Fed in designing the 2-Gates Project.” 
 
He emphasized that the group is also very concerned about the speed with which the agencies are implementing the project without concern for proper public input. 
 
“There is a very short time-line on the 2-Gates Project. It is on an extremely fast-track for installation targeted for the gates by this November!,” stated Breninger. 
 
Roger Mammon, board member of Restore the Delta, echoed Breninger's concerns about the Two Gates Project blocking navigable waterways, as well as being part of a plan by agribusiness and southern California to increase water exports out of the Delta. 
 
"This is just the start of Southern California and corporate agriculture telling us we cannot play in our own backyard," said Mammon. "And if we want to, we have to play by their rules. Before you know it, there won't be water for Delta residents, aquatic life in our waters, Delta businesses or Delta farms. As soon as they build their Panama Canal of the Delta, they will just wait for us to dry up and blow away." 
 
CalFed, the joint state/federal organization that has presided over the collapse of Central Valley salmon and Delta fish populations while wasting billions of dollars on unsuccessful “restoration” projects, has scheduled a science panel review for 6 August 2009. Information can be found at: http://www.science.calwater.ca.gov/pdf/reviews/
Final_2_Gates_meeting_notice.pdf  
 
“Given that Delta smelt are clinging to existence by a thread, is it reasonable to embark upon a rush project to alter the hydrology of their designated critical habitat simply to get around water export restrictions imposed by the BiOp?” Jennings asked. 
 
Delta smelt, a 2 to 3 inch long fish only found in the Sacramento-San Joaquin River Delta, is an indicator species that demonstrates the health of the ecosystem. The San Francisco Bay-Delta Estuary is the largest and most significant estuary on the West Coast of the Americas and supports an array of species found up and down the coast, including Chinook salmon, steelhead, green sturgeon, starry flounder, striped bass, American shad, herring, anchovies, California halibut and Dungeness crab. 
 
During the presidential campaign and since taking office, President Barack Obama has repeatedly said that he is committed to “integrity” and “transparency” in the scientific process under his administration. 
 
“The public must be able to trust the science and scientific process informing public policy decisions," said Obama in a memorandum to the heads of executive departments and agencies on March 9, 2009. “Political officials should not suppress or alter scientific or technological findings and conclusions. To the extent permitted by law, there should be transparency in the preparation, identification and use of scientific and technological information in policy making.” 
 
Those are welcome words that many would agree with, especially after 8 years of the persistent manipulation of science to the detriment of fish and the environment under the Bush administration. However, if the Obama administration is truly committed to “integrity” and “transparency” in the scientific process, why is the Bureau of Reclamation working with the California Department of Water Resources and MWD to fast-track the construction of the Two Gates Project without regard to proper public input and the impact of the project on collapsing fish species? 
 
 
CSPA’s Concerns with the Two Gates Project 
 
Here are the concerns of Bill Jennings, executive director of the California Sportfishing Protection Alliance, with the Two Gates Project (http://www.calsport.org/7-27-09.htm): 
 
• Environmental review has been short-circuited. A Finding of No Significant Impact (FONSI) and Mitigated Negative Declaration is proposed instead of a full Environmental Impact Statement/Report - this for a project whose purpose is to keep an endangered species out of a part of its critical habitat. 
 
• Required authorizations (i.e., 404 & 401 permits, streambed authorization agreement, consistency determinations with federal BiOps, etc.) are proceeding with reckless and unprecedented haste.  
 
• The models justifying the project have never been peer-reviewed, are based upon questionable assumptions and exclude significant relevant information. 
 
• There has been no effort to determine whether the hypotheses the experiment seeks to verify could be answered in other ways that don't require major structural components and altered hydrology.  
 
• Evaluations of potential impacts to other species (salmon, steelhead, sturgeon, longfin, splittail, threadfin shad, striped bass, etc.) are cursory, if nonexistent.
 
• There is no evaluation of potential water quality impacts to non-conservative constituents (i.e., the suite of pesticides, industrial and household chemicals, oxygen demand, selenium, mercury, toxicity and other dissolved constituents) that are identified as plaguing Delta waterways. Indeed, the MWD modeling indicates that residence time and water quality problems in Old River at Tracy could increase. Data collection of constituents will be limited to salt, turbidity and chlorophyll. 
 
• Potential problems that arise, like increased predation, will be addressed on the fly by the seat-of-the-pants. 
 
• Should Delta smelt show a slight increase in abundance (for whatever reason); there will be enormous pressure to quickly ramp up exports without waiting for the scientific experiment to run its course. There can be no confidence that the Water Operations Management Team or the fishery agencies will be able to withstand that pressure.  
 
• The recent NMFS BiOp bluntly prohibited installation of the South Delta Improvement Project (SDIP) operable barriers because of numerous fishery impacts. That project was developed over the span of a decade and subject to an EIR/EIS. If the SDIP operable barriers in Grantline Canal and Old and Middle Rivers were environmentally unacceptable, what can justify the haste to install the Two Gates operable barriers? 
 
In sum: what can be the necessity of short circuiting the normal rigorous environmental review and permitting processes to hastily embark upon yet another hydraulic modification of the estuary when every previous effort has led to disastrous consequences?   
 
CSPA believes that a full EIR/EIS should be conducted and that any increased conveyance should be uncoupled from the scientific experiment. Of course, history suggests that is not likely to happen short of litigation.