“Talking Points and Unfounded Assertions”: Environmental Water Caucus finds Delta Tunnels Final EIR Lacking
From the Environmental Water Caucus via Restore the Delta:
On January 27, 2017 the Environmental Water Caucus submitted their comments on the Final Delta Tunnels EIR/EIS. Read the comments here.
In summary: EWC continues to object to and reject approval of the California WaterFix project and its predecessor, Conservation Measure 1 in the Bay Delta Conservation Plan.
Here are a few excerpts the EWC comments.
On compliance with the Delta Reform Act of 2009, EWC says:
“…lead agencies for BDCP/California WaterFix have cherry-picked their preferred provisions of the 2009 Delta Reform Act, and have excluded analysis of and compliance with California Water Code Section 85021, which states in part that it is the policy of the State of California to reduce reliance on the Delta for California’s future water needs.”On the veracity of testimony by state agencies, EWC says:
“These are pleadings of state agencies whose leadership and upper management are essentially captured by regulated interests—the most powerful and influential of those 600 or so local water agencies…”On the proposed costs of the proposed Delta Tunnels, EWC says:
“No one knows for sure, since after 10 years of planning, there is still no financing plan for various sources of funds for California WaterFix.”On environmental justice impacts of the Delta Tunnels, EWC says:
“…we are deeply concerned that the Lead Agencies have failed to demonstrate that the Tunnels project would not cause direct significant economic impacts on the environmental justice communities of the Delta region…”On claims of environmental benefits from the Delta Tunnels, EWC says:
“One of the purposes of the Tunnels Project…is to maintain Delta exports while increasing water supply reliability of the state and federal water projects that export from the Delta. This purpose is, on its face, contrary to Water Code Section 85021 of the Delta Reform Act, which commands that reliance on the Delta for California’s future water needs be reduced.”On claims the that the project requires only a water right “change” not a new permit, EWC says:
“…the nature of the diversion points for California WaterFix would take water out of Delta channels and isolate it from through-Delta flow, resulting in depletions in a different part of the Delta than now occurs. This too is a distinct difference in the nature of the diversion originally included in the state water right permits and therefore requires a new application to appropriate.”EWC concludes:
“If surface water management may be analogous to use of a checking account, and groundwater supplies a savings account, then EWC suggests that the Tunnels project is analogous to a line of credit or sub-prime loan that would encourage greater transfers of surface water through cross-Delta (north-to-south) water transfers at the expense of groundwater without the reliable prospect of surface recharge to the Sacramento Valley aquifers in the future. The Tunnels would encourage consumptive uses of imported water south-of-Delta that would not be sustainable.”The Environmental Water Caucus: AquAlliance, Butte Environmental Council, California Coastkeeper Alliance, California Save Our Streams Council, California Sportfishing Protection Alliance, California Striped Bass Association, California Water Impact Network (C-WIN), California Water Research Associates, Center for Biological Diversity, Citizens Water Watch, Clean Water Action, Desal Response Group, Earth Law Center, Environmental Justice Coalition for Water, Environmental Protection Information Center, Environmental Working Group, Food & Water Watch, Foothill Conservancy, Friends of the River, Karuk Tribe, Klamath Riverkeeper, North Coast Stream Flow Coalition, Northern California Council Federation of Fly Fishers, Pacific Coast Federation of Fishermen’s Associations, Planning and Conservation League, Restore the Delta, Sacramento River Preservation Trust, San Mateo County Democracy for America, Save the American River Association, Save the Bay Association, Sierra Club, California, Sierra Nevada Alliance, Southern California Watershed Alliance, The Bay Institute, Winnemem Wintu Tribe.
Planning and Conservation League and others groups submit supplemental comments on Cal Water Fix EIR/EIS
From the Planning and Conservation League et al:
By this supplemental comment letter, PCL and the undersigned signatory public interest organizations oppose approval of the Bay Delta Conservation Plan/California Water Fix (BDCP/CWF) and its Final Environmental Impact Report/Final Environmental Impact Statement (EIR/EIS) of December 22, 2016, including preferred alternative 4A, all other variants of the Delta Water Tunnels, and any new upstream conveyance for exporting water south. We set forth in this letter additional documentation of noncompliance with the California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA). For the reasons stated below, a new environmental analysis—one that complies with state and federal laws—is needed to achieve the objective of CEQA and NEPA for informed decision making based on accurate information about the purpose of the project, alternatives, and its full impacts.
In these supplemental comments, we focus on two broad and interactive areas of noncompliance with CEQA and NEPA: (1) the lack of an accurate, stable, and consistent project definition; and (2) the granting of preferential influence to select state and federal water contractors who would benefit most from the proposed project. Both of these shortcomings are critical and illegal flaws that disqualify the project and the EIR/EIS.
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