The Planning and Conservation League, Sierra Club, Environmental Water Caucus, California Sportfishing Protection Alliance and other environmental organizations have sent a letter to Ms. Rain Emerson of the Bureau of Reclamation, objecting to the Environmental Assessment (EA) that was prepared for Westlands Water District’s Central Valley Project interim contract renewals, and requesting that their comments be included in the record. The groups are alleging that EA is inadequate and a full Environmental Impact Statement is required by law.
In December of 2013, the Bureau of Reclamation issued an Environmental Assessment and Finding of No Significant Impact, determining that the execution of six Central Valley Project (CVP) interim renewal contracts for the contract period of March 1, 2014 through February 29, 2016 was not a major federal action that will significantly affect the quality of the human environment and therefore an environmental impact statement was not required. The six interim contracts referenced all involve Westlands Water District and represent approximately 1.2 MAF of water.
“[T]he proposed interim renewal contracts are a threat to California’s environment and constitute misguided federal policy,” the letter states. “Furthermore, the contracts and their supporting environmental documents have numerous legal deficiencies.”
The groups allege that the proposed contract renewals and environmental documents violate numbers state and federal laws and statutes, including the National Environmental Policy Act (NEPA), California Environmental Quality Act (CEQA), the Reclamation Reform Act, and the Central Valley Project Improvement Act. They allege that the EA fails to comply with NEPA by not considering alternatives, fails to comply with endangered species regulations by not enforcing existing conservation measures required under biological opinions, fails to analyze impacts to areas of origin, and doesn’t consider the impacts of the proposed actions, including subsurface drainage pollution and down-slope movement from the irrigation of upslope lands, among other things.
Furthermore, they say that the auto-renewal clauses in the present interim contracts just means that no further progress made on completion of the Final EIS for the long-term renewal contracts. “The CVPIA did not contemplate 20 – 30 years of unstudied water diversions and use by the contractors, particularly in the context of the accelerating decline in the ecosystem health of the San Francisco Bay-Sacramento-San-Joaquin Delta estuary and impending extinction of imperiled species, including the Delta Smelt, Spring-run Chinook, and Winter-run Chinook,” the letter states.
The letter urges the Bureau of Reclamation to withdrawal the proposed renewal contract and re-initiate negotiations after adequate environmental review and consultation have been completed.
Read the full text of the letter here: FINAL_WWD_2014_Interim_Contract_Renewal_Comment_LTR_
