Written by David Greenwald Tuesday, 10 July 2012 05:50
"The state should not make premature commitments to a large-scale water export project before the project has been vetted and details of the BDCP are available for public review," said State Senator Lois Wolk, a long-time advocate for the Delta and opponent of plans to build a peripheral canal.
Senator Wolk is the lead author of a letter to California Secretary for Natural Resources John Laird from 15 state legislators, including Senator Mark DeSaulnier and Assembly Members Jared Huffman, Alyson Huber, Joan Buchanan and Wesley Chesbro.
"California and the Federal Government have a long history of missteps in the Delta. We urge you to put aside proposals that advance plumbing before policy and refocus the BDCP on the many sustainable solutions that can be supported by sound science and realistic financing," reads the letter. "As our congressional colleagues have pointed out, the most recent BDCP framework raises more questions than it answers, and puts at significant risk the ecosystem and communities of Northern California, and the ratepayers of Southern California."
In a letter dated June 22 to US Secretary of the Interior from 12 Congressional representatives, including John Garamendi who currently represents much of Yolo County, and Mike Thompson who formerly did, they write, "It is our understanding that this revised proposal is designed to respond to the warnings from state and federal agencies that earlier versions of the plan would not meet statutory requirements."
They continue: "The new proposal raises far more questions than it answers, and appears to tum the maxim of 'policy before plumbing' on its head. We ask that you not finalize or formally announce this framework until a far more detailed description is made available for review."
Since the BDCP process began in 2006, they write, "we have warned that a poorly designed plan would cause significant disruptions to northern California and could increase water exports from the Bay-Delta estuary - while failing to restore the Bay-Delta ecosystem and rebuild salmon and other California fisheries as required by law."
These concerns, they argue, have been "echoed" by numerous water agencies, cities, counties and various conservation groups.
"We do not believe it is wise to commit to massive new water pumping stations and conveyance tunnels while sustainable solutions to the problems of water quality, fish and ecosystem restoration, local impacts, and water flows are made to wait," the Representatives write.
A follow-up letter on June 27, 2012 by a large number of conservation and environmental groups concurs with this letter. They believe that the diversion of the Sacramento River would "have devastating ecological and economic impacts on Sacramento Valley communities, farms, streams, and myriad species."
They note, "Departments of Interior and Commerce are poised to join with the State of California to recommend the construction of a multi-billion dollar plumbing project before defining how much it will cost, how it will be operated, or how much water it will produce without environmental damage."
"The State of California proposes construction of two world-record-size tunnels capable of taking nearly all of the average freshwater flow of the Sacramento River - 15,000 cubic feet per second - away from the San Francisco Bay Delta Estuary," they add.
Last year a panel of scientists, convened by the National Research Council (NRC) of the National Academy of Sciences, issued a scathing view which expressed significant concerns that the BDCP's scientific analysis to date continues to be inadequate.
"The National Academy of Sciences issued a scathing review of the BDCP. The independent science panel declared that the BDCP's scientific analysis is inadequate.
Scientists with the Departments of Interior and Commerce have raised "red-flag" warnings about the biological impacts of the project," the groups write.
The executive summary of their report concludes, "The Effects Analysis does not yet provide the 'big picture' necessary to evaluate how the effects of complex hydrodynamic, geophysical and ecological changes in the Bay-Delta are going to be synthetically analyzed as a system to ensure conservation and management of covered species, and that ecological processes of the Bay-Delta will be preserved and enhanced under future operations."
Instead, they write that the report "... creates the impression that the entire effort is little more than a post-hoc rationalization of a previously selected group of facilities, including an isolated [water] conveyance facility, and other measures for achieving goals and objectives that are not clearly specified."
Furthermore, "We found the present draft with only the two (of proposed nine) appendices to be somewhat confusing, incomplete and fragmented, and as a result, [to] our review seemingly premature."
Finally they find, "While we recognize that the BDCP Effects Analysis involves a large, complex process with various levels of completion and detail that have yet to be satisfactorily integrated, the Panel's Phase 1 review raises many issues that suggest the findings of the Effects Analysis could be highly uncertain under its present formulation."
"The NRC's review validates everything we have been saying for the past four years", said Gary Bobker, Program Director at The Bay Institute, a group dedicated to protecting, restoring and inspiring conservation of San Francisco Bay and its watershed. "The Delta desperately needs a comprehensive ecosystem and water supply solution, but so far BDCP has approached the problem in reverse, starting out with what export water users were willing to pay for and then seeking a justification for those initial decisions that would allow even more water to be exported from the Delta. The people of California, and our native species, deserve better than this. Hopefully the NRC review will help get BDCP back on the right track."
"There is a right way to use science, and the NRC review shows that BDCP's approach is the wrong way," said The Bay Institute's Conservation Biologist, Dr. Jonathan Rosenfield. "We can do much better than this for California's fisheries, fishermen, and farmers. There is a wealth of information available on what the problems in the Delta are, how to solve them, and what the tradeoffs are."
---David M. Greenwald reporting