The Environmental Water Caucus and 48 environmental, fishing and tribal organizations, including CSPA, submitted detailed comments on the deficiencies of the Delta Stewardship Council’s Delta Plan and Environmental Impact Report (EIR).
The Draft EIR and proposed Delta Plan perpetuate the myth that existing water exports are sustainable and suggest that “water supply reliability” is shorthand for a policy to increase Delta water exports. They are patently inconsistent with the increased Delta outflows recommended by the State Water Board in their adopted flow criteria, fail to disclose the harm to public trust resources caused by current exports, fail to consider a full range of alternatives and has selected a Proposed Project that does not comply with state law. As a result, the document fails the test of “full disclosure” required by CEQA.
The revised EIR should be withdrawn, rewritten, and re-circulated for public review and comment.