Conservation News
NCCFFF Responds to plans for the South Delta Improvements Program
By Dougald Scott
NCCFFF Responds to plans for the South Delta Improvements Program
By Dougald Scott
The following are excerpts from the final comments submitted to the Department of Water Resources by the Northern California Council of the Federation of Fly Fishers (2/7/06) regarding the South Delta Improvements Program. The complete document may be downloaded HERE.
With respect to the Draft EIR/EIS (EIR) for the South Delta Improvements Program and the water agencies' plans for physical and hydrologic modifications in the Delta (Project), we request the following:
* Withdraw the EIR.
* Immediately, reduce pumping rates and water exports commensurate with those employed circa 2000; pumping rates and water exports that (at least partially) promoted an increase in Delta Smelt abundance.
* Place a moratorium on all plans for increased pumping rates and water exports until the Delta ecosystem is recovered and self-sustaining.
* Provide for long-term ecosystem restoration measures, water quality enhancements, and levee protections with greater reliability and equitable funding; otherwise, measures that jeopardize the Delta such as pumping and water exports will not be balanced by measures that protect the Delta.
* Include an appropriate range of alternatives in all analyses involving physical and hydrologic modifications of the Delta; in particular, you should include alternatives that reduce pumping rates and water exports.
The Project Has Been Proposed At An Inappropriate Time
You have been unwise to propose the Project at this time, and you have been unresponsive to prevailing conditions. Several factors would lead prudent, responsive public agencies to delay the Project:
* The Department of Fish and Game has sounded the alarm regarding the Delta ecosystem crash, and has initiated, in concert with other State and Federal agencies, studies of the Pelagic Organism Decline. Study results will impact all decisions and evaluations regarding barriers, dredging, and water operations in the Delta.
* The courts have rejected the Calfed Record of Decision because, in part, it failed to analyze alternatives that reduce pumping rates and water exports. The cumulative impact analysis in the EIR relies heavily on the same Calfed Record of Decision. The basis of the Project will be severely undermined if the lower court decision is upheld on appeal.
* The San Luis Unit drainage problem remains unresolved. Any consideration of increased water exports should not be undertaken until this toxic impact of past water exports is resolved.
* The Biological Opinion for salmonids (in support of the Plan) has been judged inadequate from the standpoint of process (Inspector General's report), and substance/best science (Calfed Science Program report).
* The State and Federal fish and wildlife agencies are still searching for reliable, long-term, mitigation measures. The EIR relies upon existing measures that have not been effective in stemming the Delta ecosystem crash, and which are not funded for the long term.
* The stability of the Delta levee system is unreliable. You have proposed unwise infrastructure investments such as permanent barriers and unwise reliance on increased water supply reliance from the Delta, given the inherent seismic, subsidence, and erosion (piping) risks of Delta levees.
Your haste in proposing this project has risked wasting millions of dollars of taxpayer money and diverted attention away from other, important, consensus projects such as planning and implementing a strategy for Delta levees.
Fishermen And Fisherwomen Are Staunchly Opposed To The Project
Fishermen and fisherwomen spend time on the water and are typically good observers and stewards of the Delta ecosystem. We are universally convinced the Project is inappropriate at this time. In the short time available to us after the holiday season and before the hearing to receive public testimony (January 2-26, 2006), we coordinated a postcard campaign and have forwarded approximately 4,000 postcards in opposition to the Project. The outcry against this project is compelling, particularly in light of the short time we were afforded to solicit a response from our constituency.
The Purpose Of The Project Has Been Mischaracterized
The EIR contains numerous citations regarding the alleged need to provide increased pumping and water exports from the Delta. There is no need to export additional water from the Delta for the foreseeable future; your recently finalized State Water Plan (Bulletin 160) does not support these alleged needs. Additional analysis by Trinity County indicates actual demands for Delta exports will likely decrease in the future.
Permanent Barriers Negatively Impact Fish
The effect of the existing barriers has been to substantially change the circulation patterns in the South Delta:
* Smelt and other fish are trapped behind the barriers and are prevented from moving downstream as they migrate from their spawning grounds to their rearing areas.
* Since 2000, the length of time the temporary barriers have been in place each year has steadily increased; this coincides with observed fishery declines. The increased barrier deployment was required to avoid impacts on in Delta farmers as export pumping increased substantially.
We dispute the finding in the EIR that the permanent barriers will benefit Delta Smelt. The proposed permanent barriers will create an "entrainment zone" where fish may be drawn into pumps or diverted into irrigation canals. The Delta Smelt and juvenile striped bass captured in this entrainment zone will either be killed by the local agricultural diversions, or redirected to the State and Federal pumping plants. We do not believe either of these outcomes is favorable compared to a scenario of unrestricted migration.
Water Quality Is Broader Than Salinity and Dissolved Organic Carbon
The EIR has focused on salinity and dissolved organic carbon and inadequately addresses the multitude of components comprising water quality. The EIR has relied upon models designed for salinity that fundamentally cannot describe other important water quality parameters.