CSPA Comments on Delta Plan EIR at Stockton Hearing

On 25 January 2011, at a packed public hearing in Stockton California, CSPA’s Executive Director Bill Jennings presented scoping comments for the Environmental Impact Report (EIR) regarding the Delta Stewardship Council’s Delta Plan.  The Delta Plan was mandated by the state legislature, as part of the Delta Reform Act of 2009.

Among numerous recommendations, Jennings observed that:

The EIR must consider a full range of alternatives for new conveyance facilities, including no new conveyance and a full range of capacities from 3,000-15,000 cfs.  Failure to consider a full range of alternatives would sabotage the EIR at the starting gate.

Evaluation of alternative conveyance facilities must be consistent with the best available peer-reviewed science and include a protective operational scenario based upon the State Water Board and Department of Fish and Game’s recently released flow criteria.

The EIR must clarify the meaning of water supply reliability in a world where rights to water exceed many times the unimpaired flow of the entire basin.  Less reliance on the Delta cannot be simply a goal, it must be an acceptance of reality.

Delta water quality must be protected and evaluated in the EIR.  Diversion of water around the estuary will alter the fate and transport of contaminates.  It will increase residence time and pollutant concentration.  California’s water problems cannot be solved by turning the estuary into a cesspool.

Proposed mitigation and habitat restoration must be realistic and achievable.  Mitigation cannot be “deferred.”  Financing must be assured.  It must be implemented in collaboration with Delta communities.  Previous efforts to protect and restore this Delta are littered with broken promises and deferred and failed mitigation.

California cannot continue to manage its water like it does its budget.  Water supply reliability cannot be achieved without bring water use into balance with available supplies.  The Delta cannot be restored without providing significantly greater flows.  Our only viable option is to eliminate waste and to use and reuse water more efficiently.

Repeal of the Monterey Plus Amendments of the California Water Code should be evaluated in the EIR because it was the elimination of the urban preference, expansion of so-called “surplus” water and privatization of the Kern Water Bank that precipitated the recent crash of pelagic and salmonid species in the Delta.

  • The urban preference should be restored.  Water supply reliability cannot mean that Kern County, representing a fraction of one percent of the state’s population and economy should be reliably assured of the same quantity of water from the Delta that is provided to the South Coast with half the state’s population and economy.
  • Elimination of the requirement that Table A allocations in SWP contracts must conform to “safe yield” was absurd.  Table A allocations were predicated on a full build-out delivery scheme that can never occur.  Article 18b should be reinserted into state contracts.
  • The Kern Water Bank should be returned to public control.  It was the illegal privatization of the Kern Water Bank that opened the doors to a smoke-and-mirrors manipulation of the system.
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