On 14 January 2014, CSPA and a coalition of environmental and fishing organizations submitted comments on six interim contract renewals for the delivery of 1,192,948 million acre feet of Central Valley Project (CVP) water to Westlands Water District. The comments pointed out numerous inadequacies in the Environmental Assessment (EA) and call for a full Environmental Impact Statement (EIS), as required by law.
The most fundamental deficiency of the EA is the failure to consider alternatives. Other inadequacies include violations of the Endangered Species Act and other federal laws by failing to adhere to conservation measures, consult with the U.S. Fish and Wildlife Service or identify and analyze impacts to groundwater pollution, Areas of Origin and the Sacramento, American and Trinity Rivers. Further, the analysis fails to accurately reflect the delivery capability of the CVP after regulatory actions under the Clean Water Act, Central Valley Project Improvement Act and Endangered Species Act are considered. The contracts are essentially based on “paper water” and fail to disclose the adverse impacts from the over commitment of CVP supplies. The EA and interim renewal contracts do not address the financial impacts from the failure to comply with payment deadlines mandated by the Coordinated Operations Act of 1986.